Revision u/s. 263 for invoking penalty provisions u/s. 270A(9)(e) without intimation u/s. 143(1)(a) untenable

KAG India Pvt Ltd. Vs PCIT (ITAT Chennai) ITAT Chennai held that revisionary proceedings under section 263 of the Income Tax Act for invoking penalty provisions u/s. 270A(9)(e) without issue of intimation under section 143(1)(a) of the Income Tax Act is unjustifiable and untenable in law. Facts- A search u/s.132 of the Act was conducted on 26.02.2021 in the assessee’s group and consequently notice u/s.153A of the Act was issued on 03.09.2021. AO made an addition of Rs.32,25,627/- by alleging that there was a difference between the undisclosed income quantified and that admitted in the return...