https://www.taxtmi.com/caselaws?id=290340 The Tribunal allowed all three appeals by the assessees, setting aside the penalties confirmed by the Commissioner of Income Tax (Appeals). It held that Explanation 3 was inapplicable as returns were filed under Section 153A, not Sections 142 or 148, and Explanation 5A did not apply as no incriminating material was found during the search. The Tribunal stressed the necessity for consistency between the Assessing Officer's satisfaction and the penalty order under Section 271(1)(c), finding discrepancies in the present case, leading to the penalties being deemed unsustainable. en-us Mon, 30 Jan 2017 00:00:00 +0530 Sun, 20 Sep 2020 16:45:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=290340 The Tribunal allowed all three appeals by the assessees, setting aside the penalties confirmed by the Commissioner of Income Tax (Appeals). It held that Explanation 3 was inapplicable as returns were filed under Section 153A, not Sections 142 or 148, and Explanation 5A did not apply as no incriminating material was found during the search. The Tribunal stressed the necessity for consistency between the Assessing Officer's satisfaction and the penalty order under Section 271(1)(c), finding discrepancies in the present case, leading to the penalties being deemed unsustainable. Case-Laws Income Tax Mon, 30 Jan 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=290340