Section 271AAB penalty upheld on Income Tax return filed belated

Jagdishbhai R. Patel Vs ACIT (ITAT Ahmedabad) CIT(A) upheld the penalty of Rs.19,50,000/-,levied u/s 271AAB of the Act @ 30% of the undisclosed income of Rs.65 lacs, noting that the assessee had failed to fulfill the following conditions by the specified date as required by the section : a) filing its return declaring the undisclosed income b) paying all taxes due thereon. That accordingly penalty @ 30% was required to be levied as per the section on account of the above failure of the assessee. The Ld.CIT(A) rejected both the contentions of the assessee of treating belated return filed u/s 13...