In Brief
A taxpayer admitted undisclosed income of ₹2,27,65,580 during a search and paid tax with interest thereon, but later disclosed additional income of ₹2,49,90,000 during assessment. The Supreme Court held that Section 271AAA(2)'s three conditions—admission, substantiation, and timely tax-interest payment—must all be satisfied to escape penalty. Penalty at 10% is not leviable on the first amount (conditions met) but is leviable on the second amount (not admitted during search). The Court clarified that "found in the course of search" has wide amplitude and includes documents obtained as a result of investigation triggered by the search.
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