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2020 (3) TMI 1412

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..... isclosure made u/s 132(4) was on the basis of any incriminating material. Therefore, the requirement that there must be undisclosed income in terms of Explanation (c) to Sec. 271AAB was not fulfilled. We find that a total disclosure of Rs.10.51 Crores was made with respect to various entities including assessee as well as Bharatkumar Parikh besides other entities. In the case of assessee, the d .....

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..... For the Revenue : Shri Lalit P Jain-Ld. DR ORDER MANOJ KUMAR AGGARWAL (ACCOUNTANT MEMBER) 1. Aforesaid appeals by assessee for Assessment Years [in short referred to as AY ] 2013-14 2014-15 contest common order of Ld. CIT(A), Ahmedabad qua confirmation of penalty u/s.271AAB. The quantum of penalty for AY 2013-14 is Rs.20 Lacs whereas the quantum of penalty for AY 2014-15 is Rs.1 .....

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..... sessee admitted disclosure of Rs.200 Lacs for AY 2013-14 and Rs.150 Lacs for AY 2014-15. The disclosure was on account of inflated expenses. The said disclosure was reflected in the returns of income for these years. Consequently, penalty proceedings u/s 271AAB, as applicable for the period of search, was initiated and the assessee was saddled with impugned penalties vide separate orders both date .....

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..... ratkumar Parikh besides other entities. In the case of assessee, the disclosure was on account of inflated expenses. However, no incriminating material was found during search operations and the undisclosed income was not represented by any money, bullion, Jewellery or other valuable article or thing or any entry in the books of accounts. None of the entries in the books was found to be false and .....

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