https://www.taxtmi.com/caselaws?id=788510 In a search assessment, the return filed under section 153A was treated as the operative return for concealment and penalty purposes, so the higher income disclosed there, without incriminating material found during the search, did not justify penalty under section 271(1)(c). The prior section 139(1) return ceased to govern once the section 153A return was furnished and accepted. The Tribunal also condoned a 1028-day delay in filing the first appeal, accepting the delay as bona fide and non-deliberate and preferring substantial justice over technical lapse. Penalty was deleted and the assessee succeeded. en-us Fri, 13 Mar 2026 00:00:00 +0530 Tue, 24 Mar 2026 08:12:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788510 In a search assessment, the return filed under section 153A was treated as the operative return for concealment and penalty purposes, so the higher income disclosed there, without incriminating material found during the search, did not justify penalty under section 271(1)(c). The prior section 139(1) return ceased to govern once the section 153A return was furnished and accepted. The Tribunal also condoned a 1028-day delay in filing the first appeal, accepting the delay as bona fide and non-deliberate and preferring substantial justice over technical lapse. Penalty was deleted and the assessee succeeded. Case-Laws Income Tax Fri, 13 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788510