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2020 (4) TMI 19 - AT - Income TaxPenalty levied u/s 271AAA - assessee has failed to substantiate the manner of undisclosed income derived - HELD THAT:- In the statement itself, the assessee has made it very clear that disclosed income is earned from business income. This is further substantiated from the fact that in its profit and loss account, the assessee has shown income from operations/sales at ₹ 18,130 lakhs which included declared business income of ₹ 75 lakhs as per Schedule 1 at page 8 of the paper book. In its reply, filed on 25.04.2011, the assessee once again made it clear that additional income is being offered for A.Y 2011-12 and this income was earned as a result of various business transactions, which were not accounted for in the books of account. This reply was filed before the DIT [INV], Panipat and submissions were reiterated before the ACIT, Central Circle, Karnal on 13.02.2013. Considering these facts on record, we are of the considered view that the assessee has fulfilled all the conditions laid down in section 271AAA of the Act. Therefore, no interference is called for. - Decided against revenue
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