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    <title>2017 (4) TMI 1425 - ITAT AHMEDABAD</title>
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    <description>The penalties imposed under section 271(1)(c) of the Income Tax Act for the assessment years 2005-06, 2008-09, and 2009-10 were deleted as the Revenue failed to demonstrate that the additional income declared was based on seized material. The Tribunal held that the deeming provision of Explanation 5A did not apply as the income was voluntarily declared without incriminating material. Consequently, all appeals of the assessee were allowed, and the penalties were deleted.</description>
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      <description>The penalties imposed under section 271(1)(c) of the Income Tax Act for the assessment years 2005-06, 2008-09, and 2009-10 were deleted as the Revenue failed to demonstrate that the additional income declared was based on seized material. The Tribunal held that the deeming provision of Explanation 5A did not apply as the income was voluntarily declared without incriminating material. Consequently, all appeals of the assessee were allowed, and the penalties were deleted.</description>
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