https://www.taxtmi.com/caselaws?id=799928 Penalty under Section 271AAA does not arise merely because physical stock of polished diamonds is lower than recorded book stock. Undisclosed income requires search material establishing income not recorded in the books. Where no search-based evidence proves that the stock discrepancy resulted from unrecorded sales or that sale consideration remained unaccounted for, the statutory conditions for penalty are not met. Confirmation of a quantum addition does not independently establish penalty liability, as penalty provisions require strict construction. The penalty was therefore deleted. en-us Thu, 17 Sep 2026 00:00:00 +0530 Tue, 29 Sep 2026 08:34:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799928 Penalty under Section 271AAA does not arise merely because physical stock of polished diamonds is lower than recorded book stock. Undisclosed income requires search material establishing income not recorded in the books. Where no search-based evidence proves that the stock discrepancy resulted from unrecorded sales or that sale consideration remained unaccounted for, the statutory conditions for penalty are not met. Confirmation of a quantum addition does not independently establish penalty liability, as penalty provisions require strict construction. The penalty was therefore deleted. Case-Laws Income Tax Thu, 17 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799928