revenue's appeal when all the conditions
specified in Section 271AAB(1)(c) of the Income Tax Act, 1961 were
satisfied for imposing ... under law, the
ITAT has erred in holding that penalty u/s. 271AAB of the Income Tax Act,
1961 is not mandatory and is discretionary
holding that penalty cannot be levied under
section 271AAB even though assessee has admitted undisclosed
income under section 132(4) of the Income ... during
the course of search when section 271AAB expressly provides
for levying of such penalty ?
b) Whether the Learned Income Tax Appellate Tribunal erred
holding that penalty cannot be levied under
section 271AAB even though assessee has admitted undisclosed
income under section 132(4) of the Income ... during
the course of search when section 271AAB expressly provides
for levying of such penalty ?
b) Whether the Learned Income Tax Appellate Tribunal erred
taken to
books subsequently does not attract penalty in terms of
Section 271AAB of the Income Tax Act, 1961.
(ii) Whether on the facts ... that the purported penalty proceedings under
Section 271 , 271AAB and 274 of the Income Tax Act, 1961
for the Assessment Year 2015-16, by penalty
both by holding that
penalty initiated by the AO U/s. 271AAB of the Act
against the deceased person is not sustainable, without
judging ... Appeals) restricting the penalty imposed by the assessing
officer under Section 271AAB only in respect of the undisclosed income
Bench,
Kolkata erred in holding that penalty cannot be levied
under section 271AAB of the Income Tax Act, 1961 during
2
the course of search ... when section 271AAB expressly
provides for levying of such penalty?
(ii) Whether on the facts and circumstances of the case,
the Learned Income Tax Appellate
