Penalty u/s 271 (1)(c) wherein additions/disallowances made under normal provisions of the Income Tax Act, 1961 but tax levied under MAT provisions u/s 115JB/115JC, for cases prior to A.Y. 2016-17

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....ral Board of Direct Taxes New Delhi, 31^st December, 2015 Subject: Penalty  u/s 271 (1)(c) wherein additions/disallowances made under normal provisions of the Income Tax Act, 1961 but tax levied under MAT provisions u/s 115JB/115JC, for cases prior to A.Y. 2016-17-reg. Section 115 JB of the Act is a special provision for levy of Minimum Alternate Tax on Companies, inserted by Finance....

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.... procedure is less than the tax payable under the deeming provisions of Section 115JB of the Act, then penalty under section 271(1)(c) of the Act could not be imposed with reference to additions /disallowances made under normal provisions. The judgment has attained finality. 4.  Subsequently, the provisions of Explanation 4 to sub-section (1) of section 271 of the Act have been substituted....