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Immunity under clause (2) of Expl. 5 to Sec 271(1)(c) available even if tax not paid by due date of ROI
Case Law Details
- Case Name
- Assistant Commissioner of Income Tax Vs M/s. Gebilal Kanhaialal HUF (Supreme Court of India)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Courts
- Supreme Court of India
Explanation 5 is a deeming provision. It provides that where, in the course of search under Section 132, the assessee is found to be the owner of unaccounted assets and the assessee claims that such assets have been acquired by him by utilizing, wholly or partly, his income for any previous year which has ended before the date of search or which is to end on or after the date of search, then, in such a situation, notwithstanding that such income is declared by him in any return of income furnished on or after the date of search, he shall be deemed to have concealed the particulars of his incom...
