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    <title>2025 (3) TMI 1871 - ITAT PATNA</title>
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    <description>Penalty under section 271AAB was found unsustainable where the amount disclosed in the return was a voluntary disclosure, not linked to any incriminating material found during search or to the statement recorded under section 132(4). The analysis notes that the disclosure was not shown to arise from any income, asset, document or transaction unearthed in search, and neither the assessment order nor the penalty order recorded satisfaction about undisclosed income. On that reasoning, the statutory ingredients for invoking section 271AAB were not treated as satisfied and the penalty was directed to be deleted.</description>
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      <link>https://www.taxtmi.com/caselaws?id=469794</link>
      <description>Penalty under section 271AAB was found unsustainable where the amount disclosed in the return was a voluntary disclosure, not linked to any incriminating material found during search or to the statement recorded under section 132(4). The analysis notes that the disclosure was not shown to arise from any income, asset, document or transaction unearthed in search, and neither the assessment order nor the penalty order recorded satisfaction about undisclosed income. On that reasoning, the statutory ingredients for invoking section 271AAB were not treated as satisfied and the penalty was directed to be deleted.</description>
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