https://www.taxtmi.com/caselaws?id=325457 The Tribunal dismissed the revenue's appeals and the assessee's petition, ruling that the assessee was entitled to immunity from penalty under Explanation 5 to Section 271(1)(c) of the Income Tax Act for all assessment years. It was held that the assessee had demonstrated the manner of deriving undisclosed income to some extent, satisfying substantial compliance with immunity clauses. The Tribunal emphasized the need for the Assessing Officer to record specific satisfaction for penalty proceedings and clarified that immunity applies to all assessment years before the search year. en-us Wed, 10 Feb 2016 00:00:00 +0530 Sat, 19 Mar 2016 08:56:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=325457 The Tribunal dismissed the revenue's appeals and the assessee's petition, ruling that the assessee was entitled to immunity from penalty under Explanation 5 to Section 271(1)(c) of the Income Tax Act for all assessment years. It was held that the assessee had demonstrated the manner of deriving undisclosed income to some extent, satisfying substantial compliance with immunity clauses. The Tribunal emphasized the need for the Assessing Officer to record specific satisfaction for penalty proceedings and clarified that immunity applies to all assessment years before the search year. Case-Laws Income Tax Wed, 10 Feb 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=325457