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    <title>1997 (7) TMI 675 - ITAT MUMBAI</title>
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    <description>The Third Member upheld the validity of penalty proceedings initiation, stating that the AO independently initiated the proceedings. The assessees were found ineligible for the Amnesty Scheme as the disclosure was prompted by incriminating material found during a search. The disclosure was deemed not voluntary, as it occurred after detection by the Department. The Third Member rejected the notion of a conditional offer and accepted penalties for most assessment years, except for additional income due to valuation differences in one year.</description>
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