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    <title>2026 (5) TMI 449 - ITAT PUNE</title>
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    <description>Penalty under section 271AAB is confined to the portion of income actually established as undisclosed on the evidence, rather than the full amount of a search-related addition. Where most of the cash was already accepted as arising from regular sales, only the balance unexplained amount could support penalty. The excess jewellery stock addition was also not fully sustainable because the search inventory and departmental records did not properly establish that alleged undisclosed stock. Penalty proceedings are independent of assessment proceedings, so the taxpayer may raise fresh contentions even if the assessment order was not challenged.</description>
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    <pubDate>Wed, 15 Apr 2026 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=791247</link>
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      <pubDate>Wed, 15 Apr 2026 00:00:00 +0530</pubDate>
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