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In the result appeal of the assessee is hereby allowed
Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalasstt. Sr.No.
penalty under section 271(1)(c) for Rs. 7,72,500/- on the additional income offered in the return filed under section 153A of the Act. 28. The necessary facts are that the assessee was subject to the search proceedings dated 4th December 2014 and therefore, the proceedings u/s 153A of the Act were initiated vide notice dated 22nd July