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Appeal dismissed.Subsection (2) of section 271AAA imposes an additional condition of the assessee having to substantiate the manner in which, the undisclosed income was derived.

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Section 132, 271AAA, 271AAA(2) of the Income Tax Act, 1961– Penalty – Concealment penalty – Exception from levy of penalty – Assessee admits undisclosed income and specifies manner in which such income was derived and there was failure on part of officer of raiding party to elicit a response from assessee as regards the manner of deriving income, merely because assessee failed to specify the manner in which the income was derived was not a ground to deny benefit of exception – Principal Commissioner of Income Tax (2019) 420 ITR 305(Gujarat)

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