‘No Addition, No Penalty’ – Section 271E Penalty Invalidated by ITAT Agra

ACIT Vs Saurabh Gupta (ITAT Agra) The case before the Income Tax Appellate Tribunal Agra involved an appeal by the revenue against the deletion of a penalty imposed under Section 271E of the Income Tax Act, 1961 for Assessment Year 2017–18. The penalty of ₹91,10,400 had been levied for alleged violation of Section 269T, based on an addition made under Section 69A read with Section 115BBE on account of unexplained money. This addition arose from documents seized during a search conducted on 26.09.2017 in a related group case. The assessee had originally filed a return declaring income of â‚...