Penalty cannot be levied by treating old jewellery found in locker as undisclosed income

Shri Padam Chand Pungliya Vs ACIT (ITAT Jaipur) Conclusion: Penalty under section 271AAB could not be imposed on assessee as old jewellery found in the locker of assessee and family members could not be treated as undisclosed for the purpose of levying penalty. Held: Department recovered some jewellery from assessee during the course of search proceedings and brought the same under the head ‘undisclosed income’ by observing that it represented the bullion and valuable articles and in the absence of the same found recorded in the books of account of assessee it was undisclosed income as per...