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    <title>2023 (12) TMI 978 - ITAT RAJKOT</title>
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    <description>The ITAT Rajkot held that penalty under section 271AAB was not sustainable where the assessee offered additional agricultural income during search proceedings. The tribunal found that additional income declared by the assessee could not be termed as &quot;undisclosed income&quot; under the statutory definition, which requires nexus with seized materials like money, bullion, jewellery or incriminating documents. Since no such materials were found linking to the additional income offered, and disclosures made during search proceedings under section 132(4) cannot automatically constitute undisclosed income, the penalty was deleted in favour of the assessee.</description>
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    <pubDate>Wed, 20 Dec 2023 00:00:00 +0530</pubDate>
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      <title>2023 (12) TMI 978 - ITAT RAJKOT</title>
      <link>https://www.taxtmi.com/caselaws?id=447294</link>
      <description>The ITAT Rajkot held that penalty under section 271AAB was not sustainable where the assessee offered additional agricultural income during search proceedings. The tribunal found that additional income declared by the assessee could not be termed as &quot;undisclosed income&quot; under the statutory definition, which requires nexus with seized materials like money, bullion, jewellery or incriminating documents. Since no such materials were found linking to the additional income offered, and disclosures made during search proceedings under section 132(4) cannot automatically constitute undisclosed income, the penalty was deleted in favour of the assessee.</description>
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      <pubDate>Wed, 20 Dec 2023 00:00:00 +0530</pubDate>
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