“Common Family Cash Pool” Theory Fails: Mumbai ITAT Upholds Section 271AAA Penalty

Kishore Avarsekar Vs DCIT (ITAT Mumbai) “Common family cash pool” theory fails – Mumbai ITAT upholds penalty u/s 271AAA for failure to substantiate undisclosed income In a significant ruling, the Mumbai ITAT upheld penalty of ₹9.57 lakh levied u/s 271AAA after holding that merely admitting undisclosed income during search is not sufficient unless the assessee also substantiates the manner in which such income was derived. The case arose from a search and seizure action u/s 132 conducted in the Unity Infraprojects Group, during which incriminating documents relating to purchase of l...