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In the result, the appeal of the assessee is allowed
Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma
3 of the assessment order has admitted that the disclosure made under Section 132(4) of Rs.65 lakh was duly included in the return of income and assessed without any demur. The Assessing Officer however observed that without search, such disclosure would not have come and therefore, he is satisfied that assessee is liable to pay penalty under Section 271