2025 (8) TMI 206

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.... appeal in ITA No.2487/Del/2023 for AY 2013-14, arises out of the order of the Commissioner of Income Tax (Appeals)-26, New Delhi [hereinafter referred to as 'ld. CIT(A)', in short] in Appeal No. 10098/2012-13 dated 04.07.2023 against the order of assessment passed u/s 271AAB(1) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act') dated 25.03.2022 by the Assessing Officer, ACIT, Cent....

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....of Rs. 1,05,45,78,526/- after making an addition u/s 69A of the Act on the basis of seized documents to the tune of Rs. 40 lakhs and Rs. 45 lakhs. At the time of search, a statement was recorded from the Managing Director Shri Manohar Singh Narula on 29.08.2012 wherein, in response to Question No. 28 the Managing Director came forward to offer total sum of Rs. 75 crores (Rs. 45 + Rs 30 crores) to ....

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....f penalty u/s 271AAB of the Act is discretionary and not mandatory. 5. We find in the instant case that the assessee had surrendered a sum of Rs. 28.24 crores in the statement u/s 132(4) of the Act and had duly honored the same by offering it in the return of income after due payment of taxes thereon. The assessee could not substantiate the manner in which such additional income was received. Hen....