https://www.taxtmi.com/caselaws?id=468414 Penalty under section 271(1)(c) was held unsustainable where the seized document relied on for the addition showed the alleged on-money was received in an earlier year, not in assessment year 2010-11. The Tribunal held that penalty proceedings are distinct from assessment proceedings, so the assessee could contest the year of taxability in penalty proceedings. As the seized material bore an earlier date and did not show payment in the relevant previous year, the basis for penalty in that assessment year failed and the penalty was deleted. en-us Tue, 13 Feb 2024 00:00:00 +0530 Tue, 05 May 2026 17:21:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468414 Penalty under section 271(1)(c) was held unsustainable where the seized document relied on for the addition showed the alleged on-money was received in an earlier year, not in assessment year 2010-11. The Tribunal held that penalty proceedings are distinct from assessment proceedings, so the assessee could contest the year of taxability in penalty proceedings. As the seized material bore an earlier date and did not show payment in the relevant previous year, the basis for penalty in that assessment year failed and the penalty was deleted. Case-Laws Income Tax Tue, 13 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468414