No Penalty Imposed u/s 271(1)(c) as Assessee Not Proven Owner of Undisclosed Income for Land Purchases.

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....Penalty u/s 271(1)(c) - the fact that the assessee and his son have declared the undisclosed income in their individual return of income and have paid taxes but capital expenditure and payment towards purchase of land cannot be held as undisclosed income in the hands of the assessee - no penalty under explanation 5A to section 271(1)(c) unless assessee is owner of the undisclosed income....