Penalty can be levied on same ground on which proceedings was initiated

Sam India Builtwell (P) Ltd. Vs DCIT (ITAT Delhi) The issue under consideration is whether the penalty levied under section 271AAA is justified in law? In the present case, AO initiated penalty proceedings under section 271AAA for explaining the manner in which undisclosed income was derived but levied penalty for assessee’s failure to substantiate the manner in which unaccounted income was earned. ITAT states that, disclosure of manner in which undisclosed income was earned and substantiating the manner in which undisclosed income was earned are two different things. Hence, there is no ...