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    <title>2021 (6) TMI 99 - ITAT DELHI</title>
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    <description>For completed assessments under section 153A, additions are sustainable only when supported by incriminating material found during search; here, the search record and panchanamas did not reveal any material linking the assessee to the alleged foreign bank account, deposits, or interest, and later Swiss-authority information did not cover the years in dispute, so the additions were deleted. Penalty under section 271(1)(c) could not survive after deletion of the quantum additions, and the penalty notice was also defective because it did not specify whether concealment of income or furnishing of inaccurate particulars was alleged, so the penalty was cancelled.</description>
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      <link>https://www.taxtmi.com/caselaws?id=408203</link>
      <description>For completed assessments under section 153A, additions are sustainable only when supported by incriminating material found during search; here, the search record and panchanamas did not reveal any material linking the assessee to the alleged foreign bank account, deposits, or interest, and later Swiss-authority information did not cover the years in dispute, so the additions were deleted. Penalty under section 271(1)(c) could not survive after deletion of the quantum additions, and the penalty notice was also defective because it did not specify whether concealment of income or furnishing of inaccurate particulars was alleged, so the penalty was cancelled.</description>
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