U/S 69 BASED ON SEIZED DOCUMENTS IS ITSELF DISPUTED AND UNDER CHALLENGE, AND NO PENALTY UNDER SECTION 271(1) (C) SHOULD HAVE BEEN LEVIED UNTIL FINALITY OF ASSESSMENT ON SUCH ADDITION. 7 THAT THE LEARNED CIT(A) NFAC HAS FAILED TO GIVE PROPER CONSIDERATION TO THE EXPLANATION AND SUPPORTING DOCUMENTS FURNISHED BY THE APPELLANT, THEREBY VIOLATING PRINCIPLES OF NATURAL JUSTICE