Penalty U/Sec. 271E on the basis of noting on seized papers

The assessee is a company wherein in the assessment completed u/s 143(3) of the Act for A.Y 2021-22, addition of Rs. 70,00,000/- was made u/s 68 of the Act on account of unaccounted cash loan repayments on the basis of noting on seize papers found during the course of search conducted in the year 2021-2022. The director of the company has accepted the above referred seize paper noting in his personal capacity. However, AO has made an addition of Rs. 70,00,000/- as undisclosed income in the hands of assessee company and similar addition has been made on the protective basis…

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