Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from original return.

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....Unreconciled jewellery found during a search may constitute undisclosed income where it cannot be matched with wealth-tax returns, valuation reports or contemporaneous records and is admitted as unrecorded income in a statement under section 132(4). A claim of acquisition in earlier years requires material establishing its source and period of acquisition. For income disclosed during search, the concessional 10% penalty rate under section 271AAB(1)(a) applies where the asset and income are specifically identified, tax is paid, and the income is included in a revised return before assessment completion. Omission from the original return does not automatically require the residuary 30% rate when substantive conditions for concessional treatment are met.....