https://www.taxtmi.com/caselaws?id=460752 Section 271AAA penalty applies in search cases unless the assessee cumulatively satisfies all three exemption conditions in sub-section (2). The Karnataka HC noted that tax and interest on the undisclosed income were paid belatedly, so the third condition was not met. Because the statutory scheme requires full compliance with every condition, the exemption did not apply and the penalty remained attracted. The court also held that the Act does not permit proportionate reduction of the penalty once the conditions for relief are not fully satisfied. The appeal therefore failed and the Revenue's position was upheld. en-us Tue, 02 Aug 2022 00:00:00 +0530 Tue, 18 Mar 2025 16:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=460752 Section 271AAA penalty applies in search cases unless the assessee cumulatively satisfies all three exemption conditions in sub-section (2). The Karnataka HC noted that tax and interest on the undisclosed income were paid belatedly, so the third condition was not met. Because the statutory scheme requires full compliance with every condition, the exemption did not apply and the penalty remained attracted. The court also held that the Act does not permit proportionate reduction of the penalty once the conditions for relief are not fully satisfied. The appeal therefore failed and the Revenue's position was upheld. Case-Laws Income Tax Tue, 02 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=460752