INCOME TAX: PENALTIES IN SEARCH CASES

Default in complying with provisions of or with conditions prescribed under the Income-tax Act would attract certain penalty and in critical cases prosecutions as well. There are three modes built in the fiscal legislation for encouraging tax compliance:

(a) Charge of Interest;

(b) Imposition of penalty;

While charging of interest is compensatory on character, the imposition of penalty and institution of prosecution proceedings act as strong deterrents against potential tax delinquents. Chapter XXI of Income-tax Act, 1961, contain various provisions empowering an Income-tax Authority to levy penalty in case of certain defaults in search cases.

Penalty in case of Search

At present, the penalty provisions existing in Income-tax Act relating to search and seizure action carried out under section 132 of the Act are summarised as under : –

S. No.	Section	Applicability
1.	270A	Penalty for under - reporting and misreporting of income [With effect from assessment year 2017-18]
1.	271(1)(c) read with Explanation 5A [Applicable upto assessment year 2016-17]	Applicable to search initiated on or after 01.06.2007 and for the years other than specified previous years defined in section 271AAA / 271AAB (1) / (1A)
2.	271AAA	Applicable to Search carried out on or after 01.06.2007 but before 01.07.2012 AND for specified previous years.
	271AAB (1)	Applicable for search initiated on or after 01.07.2012 but before 15.12.2016 AND for specified previous years
	271AAB (1A)	Applicable for search initiated on or after 15.12.2016 AND for specified previous years

(1) Penalty for under - reporting and misreporting of income [Section 270A]

[With effect from assessment year 2017-18]

Section 270A has been inserted by the Finnce Act, 2016, with effect from 01.04.2017 i.e. from the assessment year 2017-18. Under this section, the Assessing Officer, CIT (Appeals) or Principal CIT or CIT may, during the course of any proceedings under the Act, levy penalty if a person has under-reported his income. The penalty may range from 50% to 200%.

Under-reported income [Section 270A(2)]

A person shall be considered to have under-reported his income, if –

(a) the income assessed is greater than the income determined in the return processed under clause (a) of sub-section (1) of section 143;

(b) the income assessed is greater than the maximum amount not chargeable to tax, where no return of income has been furnished;

(d) the amount of deemed total income assessed or reassessed as per the provisions of section 115JB or section 115JC, as the case may be, is greater than the deemed total income determined in the return processed under clause (a) of sub-section (1) of section 143;

(e) the amount of deemed total income assessed as per the provisions of section 115JB or section 115JC is greater than the maximum amount not chargeable to tax, where no return of income has been filed;

(f) the amount of deemed total income reassessed as per the provisions of section 115JB or section 115JC, as the case may be, is greater than the deemed total income assessed or reassessed immediately before such, reassessment;

(g) the income assessed or reassessed has the effect of reducing the loss or converting such loss into income.

Computation of under- reported income [Section 270A(3)]

(i) Income is assessed for the first time

(a) Return is furnished

Ø Assessed income – Income as per intimation under section 143(1)(a)

(b) Return is not furnished

(A) In the case of a Company, firm or local authority

Ø Assessed income

(B) Others

Ø Assessed Income – Maximum amount not chargeable to tax

(ii) Income is reassessed

(a) Reassessed income – Assessed income as per preceeding order

(b) Loss case

Ø Difference between income or loss assessed and loss claimed

Intangible Addition Section 270A (4) & (5)

Section 270A(4) is somewhat similar to erstwhile explanation 2 to section 271(1) and provides that where the source of any receipt, deposit or investment in any assessment year is claimed to be an amount added to income or deducted while computing loss, as the case may be, in any preceding assessment year and no penalty was levied in such preceding assessment year then, the underreported income shall include such amount as is sufficient to cover such receipt, deposit or investment.

Further, section 270A(5) specifies that the amount for the purpose of subsection (4) shall firstly be from the immediately preceding assessment year and then from the year preceding that and so on.

Under-reporting exclusions - Addition to returned Income – No Under-Reported Income [Section 270A(6)]

Section 270A(6) prescribe following six situations, when addition to retuned income will not be considered as under-reported income.

(i) Bona fide

(a) Assessee offer an explanation

(b) Assessee should have disclosed all material facts to substantiate the explanation

(c) the Assessing Officer/CIT or PCIT/CIT(A) is satisfied that the explanation is bona fide and the assessee has disclosed all the material facts to substantiate the explanation offered

(ii) Estimated amount of under-reported income if :

(a) Amounts are correct and complete

(b) But method employed is such that income cannot be deducted therefrom

(iii) Estimated amount of under-reported income if :

(a) Ahas estimated addition/ disallowance on same issue but on a lower side

(b) offered to tax such lower amount

(iv) Additions on account of ALP (arm’s length price) determined by Transfer Pricing Officer (TPO)

The amount of under-reported income is represented by any Transfer Pricing addition made in conformity with the ALP (arm’s length price) determined by the Transfer Pricing Officer, where the assessee had maintained information and documents as prescribed under section 92D, declared the international transaction under Chapter X, and, disclosed all the material facts relating to the transaction Transfer Pricing adjustments of information maintained, transaction reported ad disclosure of facts

(v) Search cases covered by Section 271AAB

The amount of undisclosed income referred to in section 271AAB

Penalty For Under-Reporting [Section 270A(7)]

The penalty referred to in section 270A(1) shall be a sum equal to 50% of the amount of tax payable on under-reported income

Where the under-reporting is because of misreporting than provision of Section 270A(6) shall not apply [Section 270A(8)]

Section 270A(8) provides that incase where the under-reporting is because of misreporting than provision of sub-section(6) shall not apply (i.e. exceptions not applicable in case of Misreporting) and also that the penalty shall be levied at 200% of the amount of tax payable on under reported income.

“Misreporting of income” means [Section 270A(9)]

As per section 270A(9), the cases of misreporting of income reffered to in section 270A(8) shall be the following namely:-

(a) Misrepresentation or suppression of facts;

(b) Failure to record investments in the books of account;

(d) Recording of any false entry in the books of account;

(e) Failure to record any receipt in books of account having a bearing on total income; and

(f) Failure to report any international transaction or any transaction deemed to be an international transaction or any specified domestic transaction, to which the provisions of Chapter X apply.

KEY NOTE

In the above cases penalty @ 200% of the tax leviable on the amount of Unreported Income. Under-reporting shall be considered as misreporting.

Tax payable in respect of the under-reported income [Section 270A(10)]

The tax payable in respect of the under-reported income shall be—

(a) where no return of income has been furnished and the income has been assessed for the first time, the amount of tax calculated on the under-reported income as increased by the maximum amount not chargeable to tax as if it were the total income;

(b) where the total income determined under clause (a) of sub-section (1) of section 143 or assessed, reassessed or recomputed in a preceding order is a loss, the amount of tax calculated on the under-reported income as if it were the total income;

(X - Y)

where,

X = the amount of tax calculated on the under-reported income as increased by the total income determined under clause (a) of sub-section (1) of section 143 or total income assessed, reassessed or recomputed in a preceding order as if it were the total income; and

Y = the amount of tax calculated on the total income determined under clause (a) of sub-section (1) of section 143 or total income assessed, reassessed or recomputed in a preceding order.

Quantum of penalty that can be levied under section 270A

If income is under-reported due to misreporting of income, then penalty shall be levied at 200% of tax payable on such under-reported income.However, if income is under-reported due to any other circumstances, then penalty shall be 50% of tax payable on under-reported income.

In case of under reporting	50% of the amount of tax payable on the under reported income
In case of Misreporting of income	200% of the amount of tax payable on under reported income

KEY NOTE

For Example

If your income is say Rs. 20,00,000 and you have not reported an income of Rs 4,00,000 while filing your ITR. Then Assessing Officer can impose a penalty under section 270A of about Rs 60,000 (50% of the tax on under-reported income, i.e., Rs 1,20,000 (400000*30%)). However, If the under reporting is due to misreporting of income then penalty can be up to 200% of the tax on unreported income. That means 200% of Rs. 1,20,000 (400000*30%) amounting to Rs. 2,40,000.

Penalty under section 271(1)(c) of the Income-tax Act, 1961, read with the Explanation 5A thereof [Applicable upto Assessment year 2016-17]

Penalty under section 271(1)(c) of the Act, is leviable for concealment of income or furnishing inaccurate particulars of such income. Whereas, Explanation 5A creates a deeming fiction in respect of undisclosed income/assets declared during the course of search as follows:

Where undisclosed asset/income is found during the course of search initiated under section 132 on or after 01.06.2007 for any previous year which has ended before the date of search and,—

(a)	where the return of income for such previous year has been furnished before the said date but such income has not been declared therein; or
(b)	the due date for filing the return of income for such previous year has expired but the assessee has not filed the return,

then, notwithstanding that such income is declared by him in any return of income furnished on or after the date of search, he shall, for the purposes of imposition of a penalty under section 271(1)(c), be deemed to have concealed the particulars of his income or furnished inaccurate particulars of such income.

Text of Explanation 5A to Section 271(1)(c)

Explanation 5A.—Where, in the course of a search initiated under section 132 on or after the 1st day of June, 2007, the assessee is found to be the owner of—

(i ) any money, bullion, jewellery or other valuable article or thing (hereafter in this Explanation referred to as assets) and the assessee claims that such assets have been acquired by him by utilising (wholly or in part) his income for any previous year; or

(ii ) any income based on any entry in any books of account or other documents or transactions and he claims that such entry in the books of account or other documents or transactions represents his income (wholly or in part) for any previous year,

which has ended before the date of search and,—

(a) where the return of income for such previous year has been furnished before the said date but such income has not been declared therein; or

(b) the due date for filing the return of income for such previous year has expired but the assessee has not filed the return,

then, notwithstanding that such income is declared by him in any return of income furnished on or after the date of search, he shall, for the purposes of imposition of a penalty under clause (c) of sub-section (1) of this section, be deemed to have concealed the particulars of his income or furnished inaccurate particulars of such income.

Section 271(1)(c) : Penalty – Concealment – Penalty imposed on addition made on the basis of confessional statement of assessee and supplier after search was held to be valid.

The levy of penalty was not on estimated basis but based on confessional statement of the Assessee and the supplier post the search action is based on the incriminating evidence which was revealed on the proceedings pursuant to search and seizure action that led to the addition and hence the levy of penalty is justified. However, the penalty shall be levied to the extent of tax sought to be evaded relating to the additions finally sustained by Tribunal - (Related Assessment year 2007-08 , 2008-09)

[Dr. P. Sasikumar v. CIT (2018) 163 DTR 358 (Ker)]

No penalty for mere non-reflection of Income surrendered voluntarily in ITR

In the present case, the assessee not only surrendered the income during the course of survey but also paid the tax thereon before filing the return of income. However, the assessee did not reflect the surrendered amount and tax paid thereon in the said return but when the mistake was pointed out, the assessee surrendered that income. It is well settled that the assessment proceedings and the penalty proceedings are two different and separate proceedings. Therefore, even when some addition is to be made to the income of the assessee, it is not always necessary that the penalty under section 271(1)(c) of the Act is to be levied. In the present case, it cannot be said that the surrendered income was not voluntarily and the assessee wanted to conceal the income since the tax had already been paid on the amount which was surrendered during the course of survey.

Moreover, the Assessing Officer in the notice issued under section 274 r.w.s. 271 of the Act (copy of which is placed ate page no. 28 of the assessee’s paper book) was not sure as to whether the assessee concealed the particulars of income or furnished inaccurate particulars of such income which is evident from the said notice wherein neither of the two was struck off. (Related Assessment Year : 2009-10)

[Sudhir Khandelwal v. ITO - Appeal Number : ITA No. 4950/Del/2017 - Date of Judgement : 07.05.2018 (ITAT Delhi)]

Penalty under section 271(1)(c) can not be imposed based on original Return in section 153A assessment

When the revised return is accepted and the income is assessed as per the revised income, there is no scope for penalty. In the case of Kirit Dahyabhai Patel v. ACIT, (2017) 80 Taxmann.com 162 (Guj), the Hon’ble High Court held that in view of specific provision of Section 153A, the return of income filed in response to notice under section 153A is to be considered as return filed under section 139, as the Assessing Officer has made assessment on the said return and, therefore, the return has to be considered for the purpose of penalty under section 271(1)(c) of the Act and the penalty is to be levied on the income assessed over and above the income returned under section 153A, if any. Admittedly, in this matter both the returned income and the assessed income are nil. On this ground also, we cannot sustain the penalty order. (Related Assessment Year : 2009-10) to 2013-14

(M/s OSE Infrastructure Ltd. v. ACIT Appeal Number : ITA Nos. 5891 to 5895/Del/2016 - Date of Judgement : 14.08.2018 (ITAT Delhi)

(2) Penalty under section 271AAB - where search has been initiated on or after 01.07.2012

Where search has been initiated on or after 15.12.2016 [Section 271AAB (1A)]

Section	Conditions for applicability of the penalty	Quantum of Penalty as % of Undisclosed income of specified previous year
271AAB(1A)(a)	If the following conditions are satisfied: (a) Assessee must have admitted the undisclosed income in statement recorded under section 132(4) (b) Assessee specifies & substantiates the manner in which such undisclosed income was derived (c) Pays Tax & Interest on such undisclosed income before the specified date; (d) Files the Return of Income for specified previous year declaring such undisclosed income therein	30% of undisclosed income of specified previous year
271AAB(1A)(a)	60% of undisclosed income of the specified previous year in any other case.	60% of undisclosed income of the specified previous year

Where search has been initiated on or after 01.07.2012 but before 15.12.2016 [Section 271AAB (1A)]

Section	Conditions for applicability of slab of the penalty	Quantum of Penalty as % of Undisclosed income of specified previous year
271AAB(1)(a)	If the following conditions are satisfied: (a) Assessee must have admitted the undisclosed income in statement recorded under section 132(4) (b) Assessee specifies & substantiates the manner in which such undisclosed income was derived (c) on or before the specified date— (i) pays the tax, together with interest, if any, in respect of the undisclosed income; and (ii) furnishes the return of income for the specified previous year declaring such undisclosed income therein.	10% of undisclosed income of specified previous year,
271AAB(1)(b)	If the following conditions are satisfied: (a) Assessee does not admit the undisclosed income in statement recorded under section 132(4) (b) on or before the specified date— (i) declares such income in the return of income furnished for the specified previous year; and (ii) pays the tax, together with interest, if any, in respect of the undisclosed income.	20% of undisclosed income of specified previous year,
271AAB(1)(c)	in any other case i.e. where undisclosed income of specified previous year , if it is not covered by the provisions of clauses (a) and (b) of section 271AAB(1).	30% to 90% – (Flat 60% w.e.f. 01.04.2017) of undisclosed income of specified previous year,

Penalty - Search initiated on or after 1st day of July 2012 - Levy of penalty on the basis of loose sheets found on the course of search was held to be not justified as loose sheets represented only projection -Imposition of penalty is directory and not mandatory

Dismissing the appeal of the revenue the Tribunal held that ; Levy of penalty on the basis of loose sheets found on the course of search was held to be not justified as loose sheets represented only projection .Imposition of penalty is directory and not mandatory. (Related Assessment year 2013-14)

[ACIT v. Marvel Associates. (2018) 194 TTJ 338 : 170 ITD 353 : 166 DTR 409 (ITAT Vishakha)]

Where search has been initiated before 01.07.2012

Section	Conditions for applicability of the penalty	Quantum of penalty
271AAA	· where search has been initiated before 01.07.2012 • undisclosed income found	10% of undisclosed income

Penalty-Search initiated on or after 1st day of July 2012 - Disclosure of undisclosed income - Disclosed manner of earning of income and paid tax along with interest - liable to pay penalty at 10% and not at 30%

Tribunal held that, when the assessee suomotu admitted undisclosed income and substantiated manner in which such undisclosed income was earned and had also paid tax together with interest, assessee is liable to pay penalty at rate of 10 per cent in terms of clause (a) of section 271AAB(1) but not under clause (c) at rate of 30 per cent of section 271AAB(1). (Related Assessment Year : 2013-14)

[ACIT v. Vishal Agarwal. (2019) 175 DTR 127 : 174 ITD 125 : (ITAT Kolkata); ACIT v. Shailaja Park (P) Ltd (2019) 175 DTR 127 (ITAT Kolkata); ACIT v. Vikash Agarwal (2019) 175 DTR 127 (ITAT Kolkata)]

Penalty - Search initiated on or after 1st June, 2007 – Failure to specify and substantiate manner in which undisclosed income was derived rather embarked upon mercy plea that he was making surrender to buy peace of mind and avoid litigation - levy of penalty is held to be justified

Pursuant to notice under section 153A, assessee filed its return wherein certain income was surrendered on account of unexplained investment in construction of a project and difference in stock. Assessing Officer levied the penalty for failure to specify and substantiate manner in which undisclosed income was arrived. CIT(A) confirmed the order of Assessing Officer. On appeal the Tribunal held that failure to specify and substantiate manner in which undisclosed income was derived rather embarked upon mercy plea that he was making surrender to buy peace of mind and avoid litigation- levy of penalty is held to be justified. (Related Assessment year 2009-10)

[Narsi Iron & Steel (P) Ltd. v. DCIT (2019) 175 ITD 213 (ITAT Delhi)]

Search initiated on or after 1st June, 2007 – Manner of earning the undisclosed income to be given in the statement under 132(4) only if a question is asked to that effect- Deletion of penalty is held to be justified

As per sub-section (2) of section 271AAA, no penalty is leviable under sub-section (1) if the assessee in his statement recorded under section 132(4) admits the undisclosed income, specifies the manner in which such income has been earned and satisfies certain other conditions. Held that where the assessee had admitted the undisclosed income but not specified the manner in which such income was earned in his statement under section 132(4), penalty under the section was still not leviable since the Officer had not asked a question requiring the assessee to specify the manner in which such income was earned. Appeal of revenue is dismissed .

[PCIT v. Phoenix Mills Ltd. (2019) 307 CTR 700 : 175 DTR 433 (Bom)]

Search initiated on or after 1st June, 2007 –Manner in which undisclosed income earned was not satisfied -Deletion of penalty was held to be not valid

Allowing the appeal of the revenue the Court held that ; the appellate authorities misdirected themselves in holding that the conditions under Section 271AAA(2) were satisfied by the assessee. The second condition for availing of the immunity from penalty was that the assessee should have specified in the statement under Section 132(4) the manner in which such income stood derived. The assessee had merely stated that the sums advanced were undisclosed income. However, she had not specified how she had derived that income and under what head it fell (rent, capital gains, professional or business income out of money lending, source of money, etc.). Unless such facts were mentioned with some specificity, it could not be said that the assessee had fulfilled the requirement that she had in her statement under Section 132(4), “substantiated the manner in which the undisclosed income was derived”. The order of the appellate authorities deleting the penalty was erroneous. (Related Assessment Year : 2009 -10)

[CIT v. Ritu Singal (Smt) (2018) 403 ITR 97 : 303 CTR 738 : 164 DTR 153 (Del)]

Section 271AAA : Penalty – Search initiated on or after 1st June, 2007 –When no specific query to substantiate the manner of earning undisclosed income was put forward to the assessee by the authorised officer levy of penalty was held to be not valid when the taxes were paid on the amount surrendered

Dismissing the appeal of the revenue the Tribunal held that , When no specific query to substantiate the manner of earning undisclosed income was put forward to the assessee by the authorised officer levy of penalty was held to be not valid when the taxes were paid on the amount surrendered (Related Assessment year 2010-11 )

[ACIT v. Beena Kedia (ITA No 4807/4808/Del/2015 dated 28.02.2018) (ITAT Delhi)]

Penalty under section 271AAB / 270A

PROVISIONS ILLUSTRATED

Assessment Year	Case - 1	Case -2
Date of search	24.06.2019	17.12.2019
2020-21	271AAB	271AAB
2019-20	271AAB	270A
2018-19	270A	270A
2017-18	270A	270A
2016-17	271(1)(c)	271(1)(c)
2015-16	271(1)(c)	271(1)(c)
2014-15	271(1)(c)	271(1)(c)

Time limit for passing the penalty order [Section 275]

S. No.	Particulars	Time limit for imposing penalty
1.	Where the order of the Assessing Officer is contended before the CIT(A) or ITAT
	(a) Where order is passed by CIT(A) and no appeal is made to ITAT	1 year from the end of Financial Year in which the order of CIT(A) is received
	(b) Where order is passed by the ITAT	6 months from the end of the month in which order of the ITAT
2.	Where revision application has been made under section 264	6 months from the end of the month in which revision order under section 264 is passed
3.	No appeal/ revision application has been made/filed	(a) End of Financial Year in which the assessment proceedings are completed; or (b) 6 months from the end of the month in which the penalty proceedings are initiated Ø Whichever is later

Penalty under section 271F for failure to furnish return under section 153A

Facts in brief are that for all the assessment years under consideration, notice under section 153A was issued on 21.9.2007 calling for the assessee to file his return of income. The assessee did not file his return of income under section 153A. As no return of income was filed by the assessee, penalty proceedings under section 271F of the Act for non-filing the return of income, were initiated and show cause notice was issued to the assessee. The assessee did not file any reply. Therefore, the Assessing Officer after examining the provisions of section 271F and 153A, concluded that the provisions of section 139 are applicable in respect of returns to be filed under section 153A. He, therefore, levied the penalty of Rs.5,000/- for each of the assessment years.

Ld CIT (A) following the order for the assessment year 2000-2001, confirmed the Assessing Officer’s action. Being aggrieved, the assessee was in appeal before the Tribunal. It was held that “From a bare reading of both sections, it is evident that the provisions of section 271F are attracted when a person is required to furnish the return in accordance with section 139(1) or by provisos of that section. Section 153A starts with non-obstante clause and the purpose is only to specify separate time limit for filing the return. The only distinction in section 153A is that the Assessing Officer is required to issue notice to the assessee requiring him to furnish the return within such period, as may be specified in notice, but otherwise the provisions of the Act have been made applicable accordingly, as if such return were a return required to be furnished under section 139. Therefore, all the consequences following for failure to file the return under section 139 will follow under section 153A also. We, therefore, do not find any infirmity in the order of ld CIT (A) to interfere and, accordingly, uphold the same.” (Related Assessment Years : 2001 to 2001 to 2006- 2007)

[Kashinath Tapuriah v. DCIT - Date of Judgement : 16.04.2010 (ITAT Mumbai)

Other Penalties

(1) Refusal to answer in contravention of legal obligation. [Section 272A(1)(a)]

Text of Section 272A(1)(a)

272A. (1) If any person,—

(a) being legally bound to state the truth of any matter touching the subject of his assessment, refuses to answer any question put to him by an income-tax authority in the exercise of its powers under this Act;

Quantum of penalty

Maximum : Rs. 10,000 for each such default or failure

Authority by whom leviable [Section 272(3)(a)]

Income tax authority not lower in rank than a Joint Director or a Joint Commissioner, by such income-tax authoritty

No order under this section shall be passed by any income-tax authority referred to in sub-section 272(3)(a) unless the person on whom the penalty is proposed to be imposed is given an opportunity of being heard in the matter by such authority.

(2) Refusal to sign any statement made in the course of income-tax proceedings. [Section 272A(1)(b)]

Text of Section 272A(1)(a)

272A. (1) If any person,—

(b) refuses to sign any statement made by him in the course of any proceedings under this Act, which an income-tax authority may legally require him to sign;

Quantum of penalty

Maximum : Rs. 10,000 for each such default or failure

Authority by whom leviable [Section 272(3)(a)]

Income tax authority not lower in rank than a Joint Director or a Joint Commissioner, by such income-tax authoritty

(3) Failure to attend or give evidence or produce books of accounts and documents in compliance with the requirements of summons under section 131(1) [Section 272A(1)(c)]

Text of Section 272A(1)(c)

272A. (1) If any person,—

(c) to whom a summons is issued under sub-section (1) of section 131 either to attend to give evidence or produce books of account or other documents at a certain place and time omits to attend or produce books of account or documents at the place or time.

Quantum of penalty

Maximum : Rs. 10,000 for each such default or failure

Authority by whom leviable [Section 272(3)(a)]

Income tax authority not lower in rank than a Joint Director or a Joint Commissioner, by such income-tax authoritty

Argument that penalty under section 272A(1)(c) can be levied only for non-compliance of section 131(1) and not section 131(IA) is not correct because section 131(1A) has to be read with section 131(1)

So far as the arguments of the ld. counsel for the assessee that there was a reasonable cause on the part of the assessee in not submitting the details as called for by the ADIT (Investigation) is concerned, we find from the record that there was a deliberate defiance on the part of the assessee for non- submission of the same under the pretext that some of the details are available in the records of the Income Tax Department or some of the details are available in the Website of the Ministry of Corporate Affairs. On facts, the penalty is justified because the conduct of the assessee is not bona fide. There is deliberate and complete defiance to the summons issued under section 131(1A).

[Young Indian v. ADIT – Date of pronouncement : 30.08.2018) (ITAT Delhi)]

Disclaimer: The contents of this document are solely for informational purpose. It does not constitute professional advice or a formal recommendation. While due care has been taken in preparing this document, the existence of mistakes and omissions herein is not ruled out. Neither the author nor its affiliates accepts any liabilities for any loss or damage of any kind arising out of any inaccurate or incomplete information in this document nor for any actions taken in reliance thereon. No part of this document should be distributed or copied (except for personal, non-commercial use).

INCOME TAX

Friday 22 March 2019

PENALTIES IN SEARCH CASES

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