Penalty u/s 271AAB Upheld: Admission of ₹3 Crores in Search Held ‘Undisclosed Income’

S. R. Ravishankar Vs ACIT (ITAT Bangalore) Search u/s 132 was conducted in Assessee’s case on 09.10.2014 in the group of R. Chandru. During statement u/s 132(4), Assessee admitted ₹3 Crores as additional income & later offered it in return filed u/s 153A, paying due taxes. AO imposed penalty of ₹30 lakhs @10% u/s 271AAB(1)(a), treating the surrendered income as “undisclosed income”. CIT(A) confirmed the penalty. Before Tribunal, Assessee argued that the disclosure was voluntary to buy peace, unsupported by any incriminating material, and therefore did not satisfy the definition o...