No Section 271AAB Penalty if Search Proceedings were not initiated on assessee

Ramavatar Mandavewala Vs JT.CIT (ITAT Mumbai) Introduction: The case of Ramavatar Mandavewala vs. JT.CIT, heard by ITAT Mumbai, centers around the imposition of a penalty under Section 271AAB of the Income-tax Act, 1961, for the Assessment Year 2013-14. The key issue revolves around the applicability of the penalty in the absence of a direct search on the assessee. Detailed Analysis: 1. Background: During a search operation on M/s Gold Sukh Safety Vaults Ltd, a locker allegedly owned by the assessee, Ramavatar Mandavewala, was found with undisclosed cash of Rs.15 lakhs. The assessee admitted o...