Penalty u/s 271AAA leviable on failure to substantiate source & manner of undisclosed income

Chetan Hasmukhbhai Vs ACIT (Central) Circle (ITAT Pune) ITAT Pune held that penalty under section 271AAA of the Income Tax Act leviable as assessee failed to substantiate the source as well as the manner of the undisclosed income. Facts- These assessees’ twin appeals both dated 19.12.2022 involving proceeding u/s 271AAA of the Income Tax Act. The assessees’ identical sole substantive grievance that arises for our apt adjudication is correctness of lower authorities action in imposing penalties under Section 271AAA of the Income Tax Act. Conclusion- We are constrained to conclude that he ha...