The issue concerns levy of a statutory penalty where income from...

The issue concerns levy of a statutory penalty where income from cash seized during search was treated as unexplained additions under the relevant unexplained income provision. The tribunal applied the statutory test linking that unexplained income to the penalty provision and found no credible explanation, reasonable cause, or material to attract the exclusionary clause; consequently the statutory conditions for non-levy were not satisfied and the penalty was sustained. Disclosure during search was held insufficient to negate liability once judicial determination classified the cash as unexplained income, and the appeal was dismissed.