https://www.taxtmi.com/caselaws?id=255002 The HC set aside the Tribunal's order restoring the penalty under Section 271(1)(c), ruling in favor of the assessee. It held that the benefit under Explanation 5 to Section 271(1)(c) is not limited to the period before the due date for filing returns under Section 139(1). The court relied on precedents establishing that if undisclosed income is admitted during search proceedings, explained, and tax with interest is paid, immunity from penalty applies regardless of return filing timing. The penalty cannot be levied on income declared in returns filed under Section 153A. Consequently, the assessee satisfied all conditions for immunity, and the penalty was rightly disallowed. en-us Wed, 03 Dec 2014 00:00:00 +0530 Mon, 06 Apr 2026 10:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=255002 The HC set aside the Tribunal's order restoring the penalty under Section 271(1)(c), ruling in favor of the assessee. It held that the benefit under Explanation 5 to Section 271(1)(c) is not limited to the period before the due date for filing returns under Section 139(1). The court relied on precedents establishing that if undisclosed income is admitted during search proceedings, explained, and tax with interest is paid, immunity from penalty applies regardless of return filing timing. The penalty cannot be levied on income declared in returns filed under Section 153A. Consequently, the assessee satisfied all conditions for immunity, and the penalty was rightly disallowed. Case-Laws Income Tax Wed, 03 Dec 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=255002