Penalty u/s 158BFA(2) Deemed Unjustified After Reduction and Recalculation of Undisclosed Income by Assessing Officer.

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....The proceedings for imposition of penalty u/s 158BFA(2) were initiated on the basis of earlier finding by the AO. However not only undisclosed income has been reduced but the basis for calculating the undisclosed income has also been changed, in our view, the imposition of penalty, was not warranted - AT....