Penalty u/s 158BFA Requires Evidence Found During Search for Block Assessment; Mere Surrender Insufficient.

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....Penalty u/s 158BFA - Block assessment - De hors the surrender, there is no evidence which could have been said to have been found as a result of the search and, therefore, the 'computation' of undisclosed income by the Assessing Officer in the block assessment proceedings is not a ground to levy penalty - AT....