Precaution during statement of Search Proceeding- Don’t forget to mention the mode of earning disclosed income
Pr. CIT v. Ritu Singal
Decision: Against the assessee.
Penalty under section 271AAA–Leviability–Condition
Assessee during the course of search offered undisclosed income amounting to Rs. 16 cores and sought immunity from penalty under section 271AAA. AO, however, levied penalty for the reason that assessee failed to substantiate the manner in which undisclosed income was derived.
Assessee clearly failed to specify as to how she derived undisclosed income and under what head it fell in (rent, capital gains, professional or business income out of money lending source of the income, etc. Unless such facts were mentioned with some specificity, it could not be said that conditions in section 271AAA(2) were satisfied by the assessee
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