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Court Upholds Addition but Rules Penalty u/s 158BFA(2) Not Automatically Applicable for Jewelry Ownership Claim.

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....Addition was confirmed by the CIT(A) and ITAT by rejecting the explanation of the assesses that the jewellery belong to mother in law and the wife of the brother in law of the assessee, does not automatically mean that penalty u/s. 158BFA(2) is leviable - AT....