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2014 (11) TMI 636 - MADRAS HIGH COURTImposition of penalty u/s 271(1)(c) – Search operation conducted in premises - no explanation offered by assessee - Held that:- The Tribunal rightly held that no explanation was offered and is not disputed - since there is no explanation offered by the assessee, the provisions of Explanation-1 to Section 271(1) of the Act will not enure to the case of the appellant – in Shri S. Sathyanarayanan Versus The Assistant Commissioner of Income Tax [2014 (9) TMI 169 - MADRAS HIGH COURT] the same issue has been decided - the assessee had not offered any explanation either during the assessment proceedings or during the penalty proceedings regarding the unexplained cash deposits - The assessee had also not disclosed the said income in the return filed in response to the notice issued u/s 153C - there was no proper explanation given by the assessee with regard to the undisclosed income and the assessee had not given any details as to how he would fall within Explanation 1 to Section 271(1)(c) of the Income Tax Act - without any material, the assessee had merely stated that the source of income was from the business run by his father and the assessee will be no avail - the assessee and his father are Directors of the entity, namely, S&S Foundations P. Ltd. - the order of the Tribunal is upheld – Decided against assessee.
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