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
appellant, all the 3 conditions provided in sub-section (2) of
section 271 AAA were met in respect of Rs 8,00,000 as well ... former, all the three conditions given in sub section (2) of section 271
AAA had been met. The latter decision was in the context
clauses (i) and (ii) of section 271AAA(2) of the Act.
5.5 The provisions of section 271 AAA read as under-
"[Penalty where search ... Explanation 5 to section 271(1)(c) of the Act. Applying the analogy to penalty u/s 271
AAA in the present case where income
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
failed to satisfy all the three conditions of sub- section 2 of section
271 AAA of the Act, accordingly assessee is not entitled to immunity ... u/s 153C and also included the same income in return filed u/s
153C. It is thus submitted that provisions of section 271 AAA
favor of the
assessee as assessee is covered by provisions of Section 271
AAA (2) as she has substantiated the total disclosure
including ... u/s 132 (4) of the
act and to disclose the manner of earnings and its
substantiation.
j. All the conditions of section 271 AAA
vide order u/s 154 / 143 (3) dated
07.03.2014. The Assessment Officer initiated penalty proceedings
under Section 271-AAA of the Act in the Assessment ... income was derived, therefore, AO
passed the impugned penalty order under Section 271 AAA read
with Section 274 of the Act.
Being aggrieved
section
271 (1) ( c) of the Act and the penalty proceedings initiated by the A.O in the
assessment order u/s. 271 ... that the AO was technically wrong to
invoke Sec.271(1)(c) instead of Sec.271 AAA , hence the penalty should be quashed
levied under section 271AAA .
1`432ACIT VS. MUNISH KUMAR GOYAL 152 ITD 453 (CHD.
TRIE) Section 271 AAA of the Income-tax Act, 1961 - Penalty ... pursuant to notice U/s. 153 A which has
been accepted by the AO, levy of penalty U/s. 271 AAA was not
justified
M/S Shree Coal Enterprises (I) Pvt. ... vs The Acit 3(1), Bhopal on 27
