Penalty u/s 271AAA Unenforceable: No Additional Undisclosed Income Found with Seized Materials During Assessment.

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....Penalty @ 10% u/s 271AAA - undisclosed income - there was no other undisclosed income to identify with the seized materials/Panchanama, the assessee while filing the return of income pursuant to section 153A - taking note that the amount has been brought to tax by the AO though not shown by the assessee in the Return of Income, the penalty u/s. 271 AAA of the Act cannot be legally sustained. - AT....