could not be said that
the provisions of sub-section (2) of Section 271-AAA of the Act had
not been adhered ... affirmed by
the Tribunal.
5. Section 271-AAA of the Act reads as follows: -
"271-AAA. Penalty where search has been initiated
Bench: Abhay S. Oka
ITEM NO.23 COURT NO.5 SECTION ... Delhi High
Court about the interpretation of sub-section 2 of
Section 271-AAA of the Income Tax Act, 1961.
Signature Not Verified
Hence
initiation of penalty proceedings u/s
271(1)(c) of the Act. Accordingly, the penalty proceedings-
initiated u/s 271 ... where search
has been carried out u/s 132 of the Act. and for necessary
reference Section 271 AAA of the Act is reproduced below
initiation of penalty proceedings u/s
271(1)(c) of the Act. Accordingly, the penalty proceedings-
initiated u/s 271 ... where search
has been carried out u/s 132 of the Act. and for necessary
reference Section 271 AAA of the Act is reproduced below
initiation of penalty proceedings u/s
271(1)(c) of the Act. Accordingly, the penalty proceedings-
initiated u/s 271 ... where search
has been carried out u/s 132 of the Act. and for necessary
reference Section 271 AAA of the Act is reproduced below
initiation of penalty proceedings u/s
271(1)(c) of the Act. Accordingly, the penalty proceedings-
initiated u/s 271 ... where search
has been carried out u/s 132 of the Act. and for necessary
reference Section 271 AAA of the Act is reproduced below
initiation of penalty proceedings u/s
271(1)(c) of the Act. Accordingly, the penalty proceedings-
initiated u/s 271 ... where search
has been carried out u/s 132 of the Act. and for necessary
reference Section 271 AAA of the Act is reproduced below
initiation of penalty proceedings u/s
271(1)(c) of the Act. Accordingly, the penalty proceedings-
initiated u/s 271 ... where search
has been carried out u/s 132 of the Act. and for necessary
reference Section 271 AAA of the Act is reproduced below
dismissed."
3. We, however, note that Section 271AAA of the Act reads as
under:-
"[271-AAA. Penalty where search has been initiated ... penalty under the provisions of clause (c) of sub-section (1)
of Section 271 shall be imposed upon the assessee in respect of the
undisclosed
2024 emanate from the penalty
imposed by the ld. Assessing Officer u/s 271(1)(c) vide his order
dated 13th September, 2022 passed ... whether the assessee is entitled for the benefit of
section 10(26)(AAA) of the Income Tax Act or not"?
4. The facts
