Penalty u/s 158BFA(2) Dropped Due to Valuation Differences in Gold and Diamonds, No Willful Default Found.

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....Penalty u/s 158BFA(2) - no willful default - additions made were only due to the difference in estimate - It is never the case of the Revenue that the undisclosed income was on account of any transaction, which was out of books but, the entire case arose out of valuation of the gold jewellery and the diamonds - no penalty....