reassessment under sub-section (3) of section 92CD;"; (vi) in clause (c), after the words "either of the said sections", the words, brackets, figures ... clause (B), after the word, figures and letters "section 271 AAA", the word, figures and letters ", section 271AAB" shall be inserted with effect from
specified by the assessee. The
provisions of sub-section (2) of section 271 AAA cast a duty upon the assessee
to specify the manner ... concerned. Unlike a case of penalty under section
271(1) (c) , section 271 AAA, without any reference to the finding or
presumptions of concealment
above section (i.e. 271AAA) it is apparent that
17
if the conditions laid down under sub section 2 of Section
271 AAA are satisfied ... concerned. Unlike in the case of penalty
under section 271(1)(c) , Section 271 AAA, without any
reference to findings or presumptions of concealment
penalty provisions of Section 271AAA was
squarely applicable in this case. The sub section (2) of Section 271 AAA
provides that:
(2) Nothing contained ... concerned. Unlike in the case of penalty under section
271(1)(c) , Section 271 AAA, without any reference to findings or
presumptions of concealment
penalty provisions of Section 271AAA was
squarely applicable in this case. The sub section (2) of Section 271 AAA
provides that:
(2) Nothing contained ... concerned. Unlike in the case of penalty under section
271(1)(c) , Section 271 AAA, without any reference to findings or
presumptions of concealment
erred in law and facts in confirming
penalty levied under section 271 AAA on an amount of Rs.
1,58.68,413/-of penalty levied ... undisclosed income as
per provisions of section 271 AAA.
3. The learned CIT (A) has erred in law and facts in confirming
penalty levied under
erred in law and facts in confirming
penalty levied under section 271 AAA on an amount of Rs.
1,58.68,413/-of penalty levied ... undisclosed income as
per provisions of section 271 AAA.
3. The learned CIT (A) has erred in law and facts in confirming
penalty levied under
erred in law and facts in confirming
penalty levied under section 271 AAA on an amount of Rs.
1,58.68,413/-of penalty levied ... undisclosed income as
per provisions of section 271 AAA.
3. The learned CIT (A) has erred in law and facts in confirming
penalty levied under
notice
reproduces the language under the scope of section 271 (1) (c)
and not section 271 AAA. Therefore, such notice is vague and
accordingly invalid ... notice
reproduces the language under the scope of section 271 (1) (c)
and not section 271 AAA. Therefore, such notice in our
opinion is vague
course of his statement
u/s 132(4), and holding that the respondent fulfilled the
conditions of section 271 AAA ... search, and holding that the respondent fulfilled
the conditions of section 271 AAA(2) of the Act.
3) That the Ld. CIT(A) has rightly
