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    <title>2026 (9) TMI 245 - ITAT MUMBAI</title>
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    <description>Unreconciled jewellery found during a search falls within undisclosed income where it is unrecorded in regular records or not disclosed before the search, and no contemporaneous evidence establishes an earlier acquisition. An admission during a section 132(4) statement and subsequent inclusion as income support that characterisation. The concessional penalty framework applies where the income is admitted during search, the relevant asset and manner of earning are identified and substantiated, tax and interest are paid, and the amount is declared in the return. Identification of the unreconciled asset may sufficiently explain the unexplained investment when no further particulars are sought during search. Omission from the original return prevents full immunity but does not necessarily require the residuary penalty rate.</description>
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      <description>Unreconciled jewellery found during a search falls within undisclosed income where it is unrecorded in regular records or not disclosed before the search, and no contemporaneous evidence establishes an earlier acquisition. An admission during a section 132(4) statement and subsequent inclusion as income support that characterisation. The concessional penalty framework applies where the income is admitted during search, the relevant asset and manner of earning are identified and substantiated, tax and interest are paid, and the amount is declared in the return. Identification of the unreconciled asset may sufficiently explain the unexplained investment when no further particulars are sought during search. Omission from the original return prevents full immunity but does not necessarily require the residuary penalty rate.</description>
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