Section 271(1)(c) Penalty Not Applicable to Income Surrendered During Surveys; Explanation 5A Limited to Search Actions.

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....Penalty u/s 271(1)(c) - income surrendered by the assessee during survey - Explanation 5A is exclusively in the case of search and seizure action u/s 132 and the said deeming provision cannot be applied in the case of survey conducted u/s 133A.....