https://www.taxtmi.com/caselaws?id=210307 The court upheld the Tribunal's decision, dismissing the appeal and affirming that the assessee was not entitled to immunity from penalty under Explanation 5 to Section 271(1)(c) for disclosures made post-search under Section 131. The court concluded that the legislative intent was for disclosures to be made during the search itself to qualify for immunity, not during subsequent assessment proceedings. Therefore, the assessee's disclosure made after the search did not meet the statutory requirements for immunity, leading to the denial of the benefit under Explanation 5. en-us Thu, 21 Jul 2011 00:00:00 +0530 Mon, 23 Apr 2012 16:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=210307 The court upheld the Tribunal's decision, dismissing the appeal and affirming that the assessee was not entitled to immunity from penalty under Explanation 5 to Section 271(1)(c) for disclosures made post-search under Section 131. The court concluded that the legislative intent was for disclosures to be made during the search itself to qualify for immunity, not during subsequent assessment proceedings. Therefore, the assessee's disclosure made after the search did not meet the statutory requirements for immunity, leading to the denial of the benefit under Explanation 5. Case-Laws Income Tax Thu, 21 Jul 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=210307