No Section 271AAB Penalty as AO failed to link disclosed income with material found during search

DCIT Vs Tanya Jaiswal (ITAT Delhi) ITAT Delhi held that penalty u/s. 271AAB of the Income Tax Act not imposable as AO failed to link additional income disclosed by the assessee with the incriminating material found during search. Thus, penalty u/s. 271AAB deleted. Facts- In penalty proceedings u/s 271AAB of the Act, the AO observed that it was found from the seized material and records that assessee had purchased property below the fair market value of the property and the value determined by the Valuation Officer at Rs.30,95,200/- which was taken as a fair market value. The difference of the ...