Search-Based Penalties Collapsed: Additions Were Only Disallowances, Not Undisclosed Income

Trig Detectives Private Limited Vs DCIT (ITAT Mumbai) Search u/s 132 was conducted on 18.07.2019 & assessments were framed u/s 153A with multiple disallowances of salary & wages, administrative expenses, 40(a)(ia), excess depreciation & interest. Assessee accepted quantum but contested penalties. Penalties u/s 271(1)(c) (AYs 2014-15 to 2016-17), 270A (AYs 2017-18 to 2019-20) & 271AAB (AY 2020-21) were upheld partly by CIT(A). Before Tribunal, Assessee argued all additions were mere disallowances with no seized material linking them to search, hence Explanation 5A to 271(1)(c), ...