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In favour of assessee.The appellant's contention that the assessee has failed to fulfill the preconditions laid down under section 271AAA(2) is devoid of merits.

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Section 271 AAA of the Income Tax Act, 1961– Penalty – Concealment penalty – Immunity from penalty – Assessee admitted undisclosed income during search proceedings and explained the sources and there was no enquiry regarding the manner in which income was earned, thus, immunity cannot be denied because of absence of such explanation – Principal Commissioner of Income Tax vs. Patdi Commercial and Investment Ltd. (2019) 420 ITR 308 (Gujarat)

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