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    <title>2026 (5) TMI 1403 - ITAT MUMBAI</title>
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    <description>Cash found during search was admitted by the assessee in a section 132(4) statement as unaccounted and undisclosed, and no satisfactory explanation for its source or manner of earning was furnished, so penalty under section 271AAB remained leviable in principle. The absence of any difference between returned income and assessed income did not defeat penalty proceedings where the disclosure was search-related and not voluntary. However, because the assessee failed to specify and substantiate the manner of derivation, the case fell under the residuary clause rather than the more lenient limbs, and the penalty had to be confined to the minimum statutory rate instead of 90%.</description>
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      <description>Cash found during search was admitted by the assessee in a section 132(4) statement as unaccounted and undisclosed, and no satisfactory explanation for its source or manner of earning was furnished, so penalty under section 271AAB remained leviable in principle. The absence of any difference between returned income and assessed income did not defeat penalty proceedings where the disclosure was search-related and not voluntary. However, because the assessee failed to specify and substantiate the manner of derivation, the case fell under the residuary clause rather than the more lenient limbs, and the penalty had to be confined to the minimum statutory rate instead of 90%.</description>
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