https://www.taxtmi.com/caselaws?id=470348 For searches initiated on or after 15 December 2016, penalty for undisclosed income is addressed under Section 271AAB(1A), rather than Section 271(1)(c) read with Explanation 5A. The note states that the two regimes have distinct statutory ingredients and evidentiary requirements. Where proceedings are initiated only under Section 271(1)(c), without notice or an opportunity to address the requirements of Section 271AAB(1A), the penalty process breaches principles of natural justice. Penalties imposed under the inapplicable provision are therefore described as unsustainable. 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 addressed under Section 271AAB(1A), rather than Section 271(1)(c) read with Explanation 5A. The note states that the two regimes have distinct statutory ingredients and evidentiary requirements. Where proceedings are initiated only under Section 271(1)(c), without notice or an opportunity to address the requirements of Section 271AAB(1A), the penalty process breaches principles of natural justice. Penalties imposed under the inapplicable provision are therefore described as unsustainable. Case-Laws Income Tax Wed, 19 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470348