CIT(A) cannot convert 271AAB into 271(1)(c)- Penalty on 153A Surrender Invalid

Sanjeev Kumar Vs ACIT (ITAT Delhi)

Jurisdictional Overreach – CIT(A) cannot convert 271AAB into 271(1)(c)- Penalty on 153A Surrender Invalid

Delhi ITAT has quashed a penalty imposed u/s 271(1)(c), granting full relief to the assessee. Assessee had originally filed his return of income u/s 153A after a search, declaring an additional surrendered amount of ₹92 lakh. AO assessed the income u/s 153A/143(3) &  initiated penalty proceedings u/s 271AAB in respect of the surrendered sum. Subsequently, a penalty order u/s 271AAB was passed, which was later d

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