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Income Tax - Highlights / Catch Notes

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Penalty u/s 271AAB/271(1)(c) - cash was seized u/s 132A - the ...


Penalty Under Income Tax Act Sections 271AAB & 271(1)(c) Requires Strict Compliance; No Assumptions Allowed for Imposition.

June 19, 2021

Case Laws     Income Tax     AT

Penalty u/s 271AAB/271(1)(c) - cash was seized u/s 132A - the discrepancies were found during the survey - Obviously, no penalty can be imposed unless the conditions stipulated in the said provisions are duly and unambiguously satisfied. Since the assessee was exposed during survey, may be, it would have not disclosed the income but for the said survey. However, there cannot be any penalty only on surmises, conjectures and possibilities. Section 271(1)(c) of the Act has to be construed strictly. - AT

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