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2010 (9) TMI 852 - ITAT, RAJKOTBlock assessment - - Assessee offered additional income in response to notice under 153A no direct link with seized material - income concealed - penalty levied - Held that:- where no material is in record that assessee furnished incorrect particulars - though case not covered by the immunity granted under Expln. 5(2) to section 271(1)(c) - Does not amounts to automatic or deemed satisfaction - levy of penalty cannot be justified.
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