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    <title>Search-based unexplained investment addition under s69B: no incriminating material, so s271AAB(1A) &#039;undisclosed income&#039; penalty deleted</title>
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    <description>Penalty under section 271AAB(1A) was examined on whether the addition made under section 69B read with section 115BBE qualified as &quot;undisclosed income&quot; under Explanation clause (c). The statutory definition mandates that such income must be evidenced by money, bullion, jewellery or other valuable article/thing, or by entries/documents/transactions found during the search under section 132; thus, discovery of incriminating material in search is a mandatory precondition. As no incriminating material was found during search to support the addition of Rs. 28 lakhs, the amount did not fall within &quot;undisclosed income,&quot; and the penalty could not be sustained; deletion of the penalty was directed and the appeal was allowed. - ITAT</description>
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    <pubDate>Tue, 23 Dec 2025 07:59:05 +0530</pubDate>
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      <title>Search-based unexplained investment addition under s69B: no incriminating material, so s271AAB(1A) &#039;undisclosed income&#039; penalty deleted</title>
      <link>https://www.taxtmi.com/highlights?id=95321</link>
      <description>Penalty under section 271AAB(1A) was examined on whether the addition made under section 69B read with section 115BBE qualified as &quot;undisclosed income&quot; under Explanation clause (c). The statutory definition mandates that such income must be evidenced by money, bullion, jewellery or other valuable article/thing, or by entries/documents/transactions found during the search under section 132; thus, discovery of incriminating material in search is a mandatory precondition. As no incriminating material was found during search to support the addition of Rs. 28 lakhs, the amount did not fall within &quot;undisclosed income,&quot; and the penalty could not be sustained; deletion of the penalty was directed and the appeal was allowed. - ITAT</description>
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      <pubDate>Tue, 23 Dec 2025 07:59:05 +0530</pubDate>
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