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In the result, assessee’s appeal is allowed
Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani
271 shall be imposed upon the assessee in respect of the undisclosed income referred to in sub-section (1), (4) The provisions of sections 274 and 275 shall, so far as may be, apply in relation to the penalty referred to in this section. Explanation. —For the purposes of this section, — (a) "undisclosed income" means— (i) any income