Penalty u/s 158BFA(2) is Discretionary; No Penalty for Additional Income Declared During Search.

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....Levy of penalty under section 158BFA(2) is discretionary and not mandatory - Undoubtedly, there was some material found during the course of search and additional income on that account was offered by the assessee and the same has been accepted by the Revenue Department but on that account, no penalty has been levied....