2020 (4) TMI 534

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....RDER PER MANISH BORAD, AM The above captioned appeal filed at the instance of the assessee pertaining to Assessment Year 2011-12 is directed against the orders of Ld. Commissioner of Income Tax (Appeals)-I (in short 'Ld.CIT(A)'], Indore dated 11.12.2018 which is arising out of the order u/s 271AAA of the Income Tax Act 1961(In short the 'Act') dated 09.03.2016 framed by ACIT-3(1), Indore. ....

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....sessee along with questionnaire. Assessment completed u/s 143(3) of the Act on 20.3.2013 making various additions and initiated penalty proceedings u/s 271AAA. Aggrieved assessee preferred appeal before Ld. CIT(A) against the penalty proceedings u/s 271AAA but could not succeed. 5. Now the assessee is in appeal before the Tribunal. 6. Ld. Counsel for the assessee referred to the written subm....

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....ery u/s 69A Rs. 2,00,000/- 2. Unexplained cash found during the Course of search Rs. 59,116/- 3. Unexplained income offered during the Course of search Rs. 12,52,670/-   Total Rs. 15,11,786/- 9. Ld. A.O computed the penalty @10% u/s 271AAA of the Act at Rs. 1,51,178/- which has been confirmed by the Ld. CIT(A). Out of the above referred additions, one relating....

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....ies the manner in which such income has been derived; (ii) substantiates the manner in which the undisclosed income was derived; and (iii) pays the tax, together with interest, if any, in respect of the undisclosed income. 11. We observe that undisclosed income of Rs. 12,52,670/- was neither offered to tax during the course of search nor it was included in the Income Tax Retur....