deeming
provisions of Explanation 5A below section 271(1)(c) and cannot
escape from liability of penalty under section 271(1 ... Explanation 5A to section 271(1)(c) of the Act, we hold the
assessee liable for penalty under section 271(1
Explanation 5A vs Pre-amended Explanation 5A :
1. Further, the assessee raised another legal argument relating to
inapplicability of amended Explanation-5A of section 271 ... amended
Explanation 5A Vs. Post-amended Explanation 5A to section 271(1)(c) of the
Act - Specifying the limb at the time of initiation
disclosure u/s 132(4), by itself cannot redeem
the appellant from deeming provisions of the explanation 5A to section
271(1 ... disclosure u/s 132(4) , by itself cannot redeem
the appellant from deeming provisions of the explanation 5A to section
271(1
levied by
the A.O. under explanation 5A to Section 271(1)(c) of the Income Tax
Act.
2. Whether on the facts and circumstances ... reproduce Explanation 5A to Section 271(1)(c) of the Act
as under:
Section 271(1)(c) [Explanation 5A.-- Where, in the course
levied by
the A.O. under explanation 5A to Section 271(1)(c) of the Income Tax
Act.
2. Whether on the facts and circumstances ... reproduce Explanation 5A to Section 271(1)(c) of the Act
as under:
Section 271(1)(c) [Explanation 5A.-- Where, in the course
5A to Sec.271(1)(c) of the Act
in the penalty notice and levied penalty u/s.271(1)(c)
Explanation 5A ... Sec.271(1)(c) rws Explanation 5A. For ready reference, we
reproduce explanation 5A to section 271(1)(c) as under:
"Explanation 5A. -- Where
filed, the
provisions of Explanation would not apply. He argued that the
provisions of Explanation 5A to Section 271(1 ... Section 271(1)(c)
read with Explanation 5A held that the provisions of
Explanation 5A to Section 271(1)(c) of the Act are applicable
erred in
holding that provisions of explanation 1 of section 271 (1 )(c) or explanation 5A
of that section does not apply to the facts ... Explanation 5A to
section 271(1)(c) of the Act had been inserted for bringing into ambit of section
271(1
fell under explanation 5A to
section 271(1)(c) of the Act, meeting all the necessary criteria
specified in section 271(1)(c) to impose ... reproduce Explanation 5A to Section 271(1)(c)
of the Act as under:
Section 271(1)(c) [Explanation 5A.-- Where, in the course
fell under explanation 5A to
section 271(1)(c) of the Act, meeting all the necessary criteria
specified in section 271(1)(c) to impose ... reproduce Explanation 5A to Section 271(1)(c)
of the Act as under:
Section 271(1)(c) [Explanation 5A.-- Where, in the course
