https://www.taxtmi.com/caselaws?id=388348 Seized cash retained and later adjusted against tax liability on disclosed undisclosed income is treated as payment from the date of seizure where the taxpayer requested adjustment. This satisfies the tax-and-interest payment condition for the concessional penalty rate under Section 271AAB(1)(a), leaving no basis for a higher penalty based on non-payment before filing the return. In quasi-criminal penalty proceedings, the Revenue cannot enlarge the basis of levy before the Tribunal by introducing a new allegation that the manner of earning undisclosed income was not specified or substantiated. The penalty remained restricted to the concessional rate. en-us Fri, 08 Nov 2019 00:00:00 +0530 Thu, 14 Nov 2019 10:34:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=388348 Seized cash retained and later adjusted against tax liability on disclosed undisclosed income is treated as payment from the date of seizure where the taxpayer requested adjustment. This satisfies the tax-and-interest payment condition for the concessional penalty rate under Section 271AAB(1)(a), leaving no basis for a higher penalty based on non-payment before filing the return. In quasi-criminal penalty proceedings, the Revenue cannot enlarge the basis of levy before the Tribunal by introducing a new allegation that the manner of earning undisclosed income was not specified or substantiated. The penalty remained restricted to the concessional rate. Case-Laws Income Tax Fri, 08 Nov 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=388348