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In the result, the appeal of the assessee is allowed
Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma
11 respect of the aforesaid undisclosed income offered on the basis of statement under Section 132(4) of the Act. 13.1. The facts and issue in the present case is identical to ITA No.2631/Del/2018 relevant to Assessment Year 2008-09(supra). The nature of default being absent in the course of assessment proceedings, the initiation of penalty proceedings