https://www.taxtmi.com/caselaws?id=388348 Seized cash retained by the Department and later adjusted against tax liability on disclosed undisclosed income was treated as effective payment for Section 271AAB purposes, so the assessee satisfied the condition for the concessional penalty rate under clause (a) and the higher rate under clause (c) was not justified. The article also notes that a penalty order cannot be sustained on a new ground first raised at the Tribunal when the original levy rested only on alleged non-payment of tax and interest before filing the return; the basis of a quasi-criminal penalty cannot be expanded at the appellate stage. The concessional 10% penalty was therefore sustained. en-us Fri, 08 Nov 2019 00:00:00 +0530 Thu, 14 Nov 2019 10:34:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=388348 Seized cash retained by the Department and later adjusted against tax liability on disclosed undisclosed income was treated as effective payment for Section 271AAB purposes, so the assessee satisfied the condition for the concessional penalty rate under clause (a) and the higher rate under clause (c) was not justified. The article also notes that a penalty order cannot be sustained on a new ground first raised at the Tribunal when the original levy rested only on alleged non-payment of tax and interest before filing the return; the basis of a quasi-criminal penalty cannot be expanded at the appellate stage. The concessional 10% penalty was therefore sustained. Case-Laws Income Tax Fri, 08 Nov 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=388348