https://www.taxtmi.com/caselaws?id=800099 Penalty under section 271AAB(1) requires a recorded finding that surrendered income falls within the statutory definition of undisclosed income; a search disclosure alone does not satisfy that requirement. The particular clause and default invoked must be specified in the penalty notice and proceedings, and failure to identify the charge invalidates the penalty process. Where the assessment is appealed, penalty proceedings must be completed within six months of receipt of the appellate order; completion beyond that period is time-barred. These independent defects render the penalty legally unsustainable. en-us Fri, 18 Sep 2026 00:00:00 +0530 Thu, 01 Oct 2026 07:40:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800099 Penalty under section 271AAB(1) requires a recorded finding that surrendered income falls within the statutory definition of undisclosed income; a search disclosure alone does not satisfy that requirement. The particular clause and default invoked must be specified in the penalty notice and proceedings, and failure to identify the charge invalidates the penalty process. Where the assessment is appealed, penalty proceedings must be completed within six months of receipt of the appellate order; completion beyond that period is time-barred. These independent defects render the penalty legally unsustainable. Case-Laws Income Tax Fri, 18 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800099