9911796707
TMI Blog2015 (12) TMI 1821X X X X Extracts X X X X X X X X Extracts X X X X ..... RAO, AM: This appeal filed by the Revenue on 2.6.2014 is against the order of the CIT (A)-38, Mumbai dated 27.2.2014 for the assessment year 2010-2011. 2. The core issue raised in this appeal relates to the levyabilty of penalty u/s 271AAA of the Act when there is no warrant in the name of the assessee initiating search and when the assessments were made u/s 153C of the Act. Briefly stated rele ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... AA of the Act. Further, Ld Counsel for the assessee brought our attention to the language of the said section 271AAA of the Act and read out that "the Assessing Officer may...........direct that, in a case where search has been initiated under section 132 on or after the 1st day of June, 2007 [but before the 1st day of July, 2012]...........". 4. On the other hand, Ld DR for the Revenue relied on ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... are relevant in this regard. Considering the importance of the relevant para 6.3 of the impugned order and for the sake of completeness of this order, the same is extracted as follows:- "6.3. In view of the above, I am of the view that the provisions of section 271AAA of the Act can be invoked only in respect of the assessee, who has been searched u/s 132 of the Act. No search u/s 132 of the Ac ..... X X X X Extracts X X X X X X X X Extracts X X X X
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