compl eting the assessment , learned assessi ng officer initiated
proceedings under section 271 AAA o f the Act and concluded them by order
dated ... filled requirement s of section 13 2
(4) and, thus, penalty order passed agai nst her under section 271 AAA wa s to
be confirmed
Appeals) failed to appreciate that the provisions of section
271 AAA of the Act had no application to the facts of the case inasmuch ... Appeals) failed to appreciate that sub-section (2) to the main
provision in section 271 AAA of the Act was wrongly interpreted and
understood
conducted.]"
(some parts italicized by us)
6. Sub-section (1) of section 271 AAA provides that penalty shall be computed @
10% of the undisclosed ... before 01-07-2012. Sub-section (3) of section 271 AAA
provides that in case penalty is imposed under sub-section (1), then the provisions
conducted.]"
(some parts italicized by us)
6. Sub-section (1) of section 271 AAA provides that penalty shall be computed @
10% of the undisclosed ... before 01-07-2012. Sub-section (3) of section 271 AAA
provides that in case penalty is imposed under sub-section (1), then the provisions
conducted.]"
(some parts italicized by us)
6. Sub-section (1) of section 271 AAA provides that penalty shall be computed @
10% of the undisclosed ... before 01-07-2012. Sub-section (3) of section 271 AAA
provides that in case penalty is imposed under sub-section (1), then the provisions
Assessment Year 2011-12 wherein the
penalty u/s 271 AAA levied by the learned Deputy Commissioner Of Income
Tax, central circle - 25, New Delhi ... well as on facts in according approval u/s 274(2) for
imposing penalty u/s 271 AAA in a mechanical manner and without
applying
facts in confirming the levy of penalty
u/s 271 AAA, more so when penalty was initiated & levied by Ld.
A.O. only ... lower
appellate authorities misdirected themselves in holding that the
conditions in Section 271 AAA (2) were satisfied by the assessee."
14. However, the instant
case is covered by the provisions of
sub-section (2) of section 271 AAA of the Act and accordingly the appellant is eligible ... entitled to the immunity provided by sub-section (2) of section 271 AAA.
2
ITA No. 1663/Mum/2017
(d) The appellant, respectfully submits that
initiated after
mentioning as "Initiate penalty u/s 271 (l)(c) . Penalty proceeding u/s 271 AAA
are also being initiated as the assessee ... concealment penalty u/s 271(l)(C) of the Act, but legal ratio would equally
apply to the section 271 AAA of the Act which
penalty of Rs.2,50,000/- by the Assessing Office u/s.
271 AAA which has been upheld by the CIT(A) is the only ... While completing
the assessment, penalty proceedings u/s 271 AAA of the Act were
initiated in respect of surrendered income made by the assessee
