Penalty u/s 271AAB Not Justified: Disallowance u/s 14A Isn't Undisclosed Income Post Search Operation.

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....Penalty u/s 271AAB(1) - disallowance u/s 14A - search and seizure - the disallowance of expenditure u/s 14A doesn’t represent any income of the specified previous year by any entry in respect of an expense recorded in the books of account or other documents maintained in the normal course relating to the specified previous year which is found to be false - there is no legal basis for sustaining the charge of undisclosed income found during the course of search and accordingly, there is no justifiable and legal basis for levy of penalty u/s 271AAB - AT....