Penalty u/s 271AAB can only be levied on a person who was subject to search

Shri D.S. Patil Vs PCIT (ITAT Banglore) Penalty u/ s. 271AAB can be levied in the hands of a searched person only. The assessee herein is not subjected to search, meaning thereby, penalty u/s. 271AAB cannot be levied in the hands of the assessee. Even though, the AO has not cited any reason for dropping penalty proceedings, yet the fact remains that the penalty u/ s. 271AAB cannot be levied in the hands of the assessee, as opined by coordinate benches. Hence, very initiation of revision proceedings is not in accordance with law and the same cannot be sustained. Even otherwise, there is possibi...