https://www.taxtmi.com/caselaws?id=470348 For searches initiated on or after 15 December 2016, penalty for undisclosed income is governed by Section 271AAB(1A), not Section 271(1)(c) read with Explanation 5A. Where a search occurred on 20 November 2019, applying the latter provision is therefore inapplicable. The two regimes have distinct statutory ingredients and evidentiary requirements. Penalty action pursued only under Section 271(1)(c), without notice or an opportunity to address the requirements of Section 271AAB(1A), breaches principles of natural justice. Penalties imposed under Section 271(1)(c) read with Explanation 5A were consequently unsustainable and quashed. en-us Wed, 19 Mar 2025 00:00:00 +0530 Thu, 23 Jul 2026 20:51:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470348 For searches initiated on or after 15 December 2016, penalty for undisclosed income is governed by Section 271AAB(1A), not Section 271(1)(c) read with Explanation 5A. Where a search occurred on 20 November 2019, applying the latter provision is therefore inapplicable. The two regimes have distinct statutory ingredients and evidentiary requirements. Penalty action pursued only under Section 271(1)(c), without notice or an opportunity to address the requirements of Section 271AAB(1A), breaches principles of natural justice. Penalties imposed under Section 271(1)(c) read with Explanation 5A were consequently unsustainable and quashed. Case-Laws Income Tax Wed, 19 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470348