Credit-note turnover adjustments preserve inverted-duty refunds, while ministerial re-computation does not constitute an impermissible appellate reman...
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Section 271AAB imposes penalty only where the amount falls within its exhaustive definition of undisclosed income; a surrender during search proceedings alone is insufficient. Diary entries recording advances indicate an outflow or application of funds, rather than unreported income, unless a corresponding undisclosed asset or source is established. Deeming rules for unexplained sums do not automatically apply to this self-contained penalty provision. The Assessing Officer must specifically establish that the amount was found in, or resulted from, the search as undisclosed income. Penalty on surrendered advances reflected in vague diary notings was therefore deleted.
Section 271AAB imposes penalty only where the amount falls within its exhaustive definition of undisclosed income; a surrender during search proceedings alone is insufficient. Diary entries recording advances indicate an outflow or application of funds, rather than unreported income, unless a corresponding undisclosed asset or source is established. Deeming rules for unexplained sums do not automatically apply to this self-contained penalty provision. The Assessing Officer must specifically establish that the amount was found in, or resulted from, the search as undisclosed income. Penalty on surrendered advances reflected in vague diary notings was therefore deleted.
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