ITAT explains Difference between Section 271(1)(c) and 271AAA

The only issue arising in the instant appeal is the maintainability or otherwise in law, and in the facts and circumstances of the case, of the deletion of the penalty levied u/s. 271AAA of the Act by the ld. CIT(A) vide his impugned order, which is in fact a combined order for A.Ys. 2004-05, 2008-09 and 2009-10. The facts of the case in brief are that there was a search and seizure action u/s. 132 of the Act in the case of Prakash Steelage group of companies, of which the assessee­ company forms a part, on 09.02.2009. Several incriminating materials were found, leading to a disclosure of und...