Jewellery Ownership Dispute: Section 271AAB Penalty Contested, Citing Collective Family Ownership and Age of Items.

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....Penalty u/s 271AAB - such jewellery found in possession of family members belongs to them and doesn’t belong to assessee alone - further, most of the jewellery found is old one - mere disclosure of such jewellery in the statement of the assessee recorded u/s 132(4) of the Act would not represent undisclosed income as defined in the explanation to section 271AAB - AT....