https://www.taxtmi.com/caselaws?id=466465 Interpretation of the proviso to section 271AAC(1) turned on whether the phrase "section 139" encompasses returns under subsection (1) or (4). The tribunal found the Finance Act 2021 amendment altering subsection references takes effect prospectively from AY 2022-23, so it does not alter the scope for AY 2021-22. Because the proviso uses the general term "section 139," it cannot be read as limited to 139(1), and an assessee who filed a return meeting the proviso's conditions cannot be penalised under the impugned provision; the penalty was deleted. en-us Thu, 27 Feb 2025 00:00:00 +0530 Mon, 09 Feb 2026 21:21:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466465 Interpretation of the proviso to section 271AAC(1) turned on whether the phrase "section 139" encompasses returns under subsection (1) or (4). The tribunal found the Finance Act 2021 amendment altering subsection references takes effect prospectively from AY 2022-23, so it does not alter the scope for AY 2021-22. Because the proviso uses the general term "section 139," it cannot be read as limited to 139(1), and an assessee who filed a return meeting the proviso's conditions cannot be penalised under the impugned provision; the penalty was deleted. Case-Laws Income Tax Thu, 27 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466465