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2015 (8) TMI 1385 - AT - Income TaxPenalty u/s 271AAA - seized or requisitioned assets against existing liability - AO was of the view that since the assessee has not paid tax on the income declared by the assessee himself, the benefit of exclusion under section 271AAA(2)(i) is not available - Held that: - Explanation 2 to section 132B, as Finance Act, 2013 clearly states is effective from 1st June, 2013. When the law so specifically states, there is no scope of holding that it is retrospective in effect - This provision restricts the scope of adjustment of seized cash, and, therefore, is to be treated as advance to the assessee - appeal dismissed - decided against Revenue.
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