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    <title>2025 (2) TMI 583 - Supreme Court</title>
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    <description>SC partly allowed the assessee&#039;s appeal on penalty under s.271AAA. It held that &quot;specified previous year&quot; was AY 2011-12 and that income of Rs. 2,27,65,580 admitted during search, with manner substantiated and tax plus interest paid (though belatedly), fulfilled s.271AAA(2), rendering penalty on this amount impermissible. However, income of Rs. 2,49,90,000 from land transactions, not admitted in the search statement and disclosed only during assessment after inquiry into sale deeds traced through the search, constituted &quot;undisclosed income&quot; found in the course of search. For this portion, the exception under s.271AAA(2) was inapplicable, and penalty at 10% under s.271AAA(1) was upheld.</description>
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    <pubDate>Thu, 13 Feb 2025 00:00:00 +0530</pubDate>
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      <title>2025 (2) TMI 583 - Supreme Court</title>
      <link>https://www.taxtmi.com/caselaws?id=766037</link>
      <description>SC partly allowed the assessee&#039;s appeal on penalty under s.271AAA. It held that &quot;specified previous year&quot; was AY 2011-12 and that income of Rs. 2,27,65,580 admitted during search, with manner substantiated and tax plus interest paid (though belatedly), fulfilled s.271AAA(2), rendering penalty on this amount impermissible. However, income of Rs. 2,49,90,000 from land transactions, not admitted in the search statement and disclosed only during assessment after inquiry into sale deeds traced through the search, constituted &quot;undisclosed income&quot; found in the course of search. For this portion, the exception under s.271AAA(2) was inapplicable, and penalty at 10% under s.271AAA(1) was upheld.</description>
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      <pubDate>Thu, 13 Feb 2025 00:00:00 +0530</pubDate>
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