Tribunal Deletes Penalty u/s 271C; Explanation 5A Applies Only to Searched Person, Not Others in Section 153C Assessment.

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....Penalty u/s 271C - assessment u/s 153C - When there was no addition to the declared income in any of the years, penalty was correctly deleted by the Tribunal. Explanation 5A below Section 271 would apply only in case of searched person, it cannot be extended to the person other than the searched person....