Penalty u/s 271AAA Not Upheld Due to Unsubstantiated Allegations on Surrendered Income and Its Derivation.

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....Levy of penalty u/s 271AAA - allegation that, assessee had not accounted for this surrendered income in his books of account on the date of search and further the assessee has failed to specify the manner in which such income has been derived and even failed to substantiate such manner, is not correct - no penalty - AT....