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“penalty under section 271AAB”

PenaltySection 271AABSection 271AAB112 judgments

SATISH KUMAR ARORA,AGRA vs. INCOME TAX OFFICER 1(1)(2), AGRA

In the result, the appeal of the assessee is dismissed

ITA 510/AGR/2025[2014-15]Status: DisposedITAT Agra11 Feb 2026AY 2014-15

Bench: Shri M. Balaganesh & Shri Sunil Kumar Singhsatish Kumar Arora, Vs. Income Tax Officer, 1 Ashok Enclave Dayal Watd-1(1)(2), Bagh, Agra, Up Agra, Up (Appellant) (Respondent) Pan: Aampa0703C Assessee By : Shri Rajendra Sharma, Adv Shri Manuj Sharma, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 20/01/2026 Date Of Pronouncement 11/02/2026

For Appellant: Shri Rajendra Sharma, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 132Section 144Section 153ASection 271A

only issue to be decided in this appeal is as to whether the learned CIT(A) was justified in confirming the levy of penalty under section 271AAB of the Act in the facts and circumstances of the instant case. 3. We have heard the rival submissions and perused the materials ... Page 7 & 8 Page 8 & 9 assessment 8 & 9 order at page 5. The dispute before us is the levy of penalty under section 271AAB of the Act in respect of the aforesaid final additions sustained by the Tribunal. From the aforesaid chart, it is evident that income determined

SATISH KUMAR ARORA,AGRA vs. INCOME TAX OFFICER 1(1)(2), AGRA

In the result, all the appeals of the assessee are hereby dismissed

ITA 509/AGR/2025[2013-14]Status: DisposedITAT Agra03 Feb 2026AY 2013-14

Bench: Shri M. Balaganesh

For Appellant: Shri Rajendra Sharma, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 132Section 144Section 153ASection 271A

only identical issue to be decided in these appeals is as to whether the learned CITA was justified in confirming the levy of penalty under section 271AAB of the Act in the facts and circumstances of the instant case. ITA Nos. 504 to 509/AGR/2025 Satish Kumar Arora 3. I have ... Page 7 & 8 Page 8 & 9 assessment 8 & 9 order at page 5. The dispute before me is the levy of penalty under section 271AAB of the Act in respect of the aforesaid final additions sustained by the Tribunal. From the aforesaid chart, it is evident that income determined

SATISH KUMAR ARORA,AGRA vs. INCOME TAX OFFICER 1(1)(2) , AGRA

In the result, all the appeals of the assessee are hereby dismissed

ITA 508/AGR/2025[2012-13]Status: DisposedITAT Agra03 Feb 2026AY 2012-13

Bench: Shri M. Balaganesh

For Appellant: Shri Rajendra Sharma, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 132Section 144Section 153ASection 271A

only identical issue to be decided in these appeals is as to whether the learned CITA was justified in confirming the levy of penalty under section 271AAB of the Act in the facts and circumstances of the instant case. ITA Nos. 504 to 509/AGR/2025 Satish Kumar Arora 3. I have ... Page 7 & 8 Page 8 & 9 assessment 8 & 9 order at page 5. The dispute before me is the levy of penalty under section 271AAB of the Act in respect of the aforesaid final additions sustained by the Tribunal. From the aforesaid chart, it is evident that income determined

SATISH KUMAR ARORA,AGRA vs. INCOME TAX OFFICER 1(1)(2), AGRA

In the result, all the appeals of the assessee are hereby dismissed

ITA 507/AGR/2025[2011-12]Status: DisposedITAT Agra03 Feb 2026AY 2011-12

Bench: Shri M. Balaganesh

For Appellant: Shri Rajendra Sharma, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 132Section 144Section 153ASection 271A

only identical issue to be decided in these appeals is as to whether the learned CITA was justified in confirming the levy of penalty under section 271AAB of the Act in the facts and circumstances of the instant case. ITA Nos. 504 to 509/AGR/2025 Satish Kumar Arora 3. I have ... Page 7 & 8 Page 8 & 9 assessment 8 & 9 order at page 5. The dispute before me is the levy of penalty under section 271AAB of the Act in respect of the aforesaid final additions sustained by the Tribunal. From the aforesaid chart, it is evident that income determined

SATISH KUMAR ARORA,AGRA vs. INCOME TAX OFFICER 1(1)(2), AGRA

In the result, all the appeals of the assessee are hereby dismissed

ITA 506/AGR/2025[2010-11]Status: DisposedITAT Agra03 Feb 2026AY 2010-11

Bench: Shri M. Balaganesh

For Appellant: Shri Rajendra Sharma, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 132Section 144Section 153ASection 271A

only identical issue to be decided in these appeals is as to whether the learned CITA was justified in confirming the levy of penalty under section 271AAB of the Act in the facts and circumstances of the instant case. ITA Nos. 504 to 509/AGR/2025 Satish Kumar Arora 3. I have ... Page 7 & 8 Page 8 & 9 assessment 8 & 9 order at page 5. The dispute before me is the levy of penalty under section 271AAB of the Act in respect of the aforesaid final additions sustained by the Tribunal. From the aforesaid chart, it is evident that income determined

SATISH KUMAR ARORA,AGRA vs. INCOME TAX OFFICER 1(1)(2) , AGRA

In the result, all the appeals of the assessee are hereby dismissed

ITA 505/AGR/2025[2009-10]Status: DisposedITAT Agra03 Feb 2026AY 2009-10

Bench: Shri M. Balaganesh

For Appellant: Shri Rajendra Sharma, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 132Section 144Section 153ASection 271A

only identical issue to be decided in these appeals is as to whether the learned CITA was justified in confirming the levy of penalty under section 271AAB of the Act in the facts and circumstances of the instant case. ITA Nos. 504 to 509/AGR/2025 Satish Kumar Arora 3. I have ... Page 7 & 8 Page 8 & 9 assessment 8 & 9 order at page 5. The dispute before me is the levy of penalty under section 271AAB of the Act in respect of the aforesaid final additions sustained by the Tribunal. From the aforesaid chart, it is evident that income determined

SATISH KUMAR ARORA,AGRA vs. INCOME TAX OFFICER 1(1)(2) AGRA, AGRA

In the result, all the appeals of the assessee are hereby dismissed

ITA 504/AGR/2025[2008-09]Status: DisposedITAT Agra03 Feb 2026AY 2008-09

Bench: Shri M. Balaganesh

For Appellant: Shri Rajendra Sharma, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 132Section 144Section 153ASection 271A

only identical issue to be decided in these appeals is as to whether the learned CITA was justified in confirming the levy of penalty under section 271AAB of the Act in the facts and circumstances of the instant case. ITA Nos. 504 to 509/AGR/2025 Satish Kumar Arora 3. I have ... Page 7 & 8 Page 8 & 9 assessment 8 & 9 order at page 5. The dispute before me is the levy of penalty under section 271AAB of the Act in respect of the aforesaid final additions sustained by the Tribunal. From the aforesaid chart, it is evident that income determined

ACIT-CENTRAL CIRCLE-2(4), HYDERABAD vs. INCREDIBLE INDIA PROJECTS PRIVATE LIMITED, SECUNDERABAD

In the result, appeal of the Revenue is dismissed

ITA 605/HYD/2022[2018-19]Status: DisposedITAT Hyderabad30 Jan 2026AY 2018-19
For Appellant: Sri Sandeep Goel, AdvocateFor Respondent: MS U Mini Chandran, CIT-DR
Section 2Section 271ASection 274

support of his claim, the following submissions\nhave been made by the appellant's AR:\n"B. The important conditions while imposing penalty\nunder section 271AAB are as follows:\n(i) The penalty under section 271AAB is discretionary and is\nneither automatic nor mandatory as it uses the words ... nmay direct\".\n(ii) The discretionary penalty under section 271AAB (1A) can be\nlevied under clause (a) @ 30% and under clause (b) @ 60%\ndepending upon the default and charge against the\nassessee.\n(iii) Existence of 'undisclosed income' is a sine quo non for\nlevying such penalty. which is defined

DCIT, CENTRAL CIRCLE-4, NEW DELHI vs. SMC FOODS LTD, SAHARANPUR

In the result, Revenue appeal ITA No

ITA 2661/DEL/2022[2018-19]Status: DisposedITAT Delhi23 Dec 2025AY 2018-19

Bench: Shri S. Rifaur Rahman & Ms. Madhumita Royassessment Year: 2018-19

Section 132Section 132(4)Section 139(1)Section 143(2)Section 143(3)Section 271A

penalty by observing that the additional income of Rs. 6,00,00,000/- was embodied in the return of income itself and thus penalty under Section 271AAB(1A)(b) of the Act on the basis of additional income offered during the course of search. In that view of the matter ... question before us is as to whether the penalty under Section 271AAB(1A)(b) of the Act can at all be levied on additional income offered during the course of search or not. At the time of hearing of the instant appeal learned Counsel Mr. Madhur Agarwal vehemently opposed

SRINIVAS CHOWDARY VALLABHANENI,SECUNDERABAD vs. DCIT., CENTRAL CIRCLE-1(4), HYDERABAD

In the result, the appeal of the assessee is allowed

ITA 1461/HYD/2025[2019-20]Status: DisposedITAT Hyderabad19 Dec 2025AY 2019-20
For Appellant: Shri Phaneendra Nag, CAFor Respondent: : Smt. Reema Yadav, Sr. DR
Section 271Section 271ASection 274

further submitted that the\n\nPage 4 of 8\n\nITA No 1461 of 2025 Srinivas Chowdary Vallabhaneni\nLd. AO levied penalty under section 271AAB(1A) of the Act on the\naddition of Rs.28.00 lakhs. He further submitted that for penalty\nto be leviable, the income must fall within ... incriminating material\nduring search is a mandatory precondition for bringing any\nincome within the meaning of “undisclosed income" for purposes\nof levy of penalty under section 271AAB(1A) of the Act. In the\npresent case, as already recorded by this Tribunal in the quantum\nproceedings, no incriminating material was found

RAJESWARA RAO ANNE,HYDERABAD vs. DCIT., CENTRAL CIRCLE-1(4), HYDERABAD

In the result, the appeal of the assessee is allowed

ITA 1438/HYD/2025[2019-20]Status: DisposedITAT Hyderabad19 Dec 2025AY 2019-20
For Appellant: Shri Phaneendra Nag, CA
Section 11ISection 132Section 271Section 271ASection 274

lakhs and accordingly directed the Ld. AO\nto tax the said sum at normal rates. The Ld. AR argued that the\nlevy of penalty under section 271AAB(1A) of the Act presupposes\nthat the income must fall within the definition of “undisclosed\nincome” under clause (c) of the Explanation ... undisclosed income” as defined in the clause (c) of\nExplanation to section 271AAB of the Act. When the statutory\ncondition is not fulfilled, penalty under section 271AAB(1A) of the\nAct cannot be sustained. In view of the above factual and legal\nposition, and in conformity with the earlier findings

ANNE MANOJ CHOWDARY,HYDERABAD vs. DCIT., CENTER CIRCLE-1(4), HYDERABAD

In the result, the appeal of the assessee is allowed

ITA 1437/HYD/2025[2019-20]Status: DisposedITAT Hyderabad19 Dec 2025AY 2019-20

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1437/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2019-20) Shri Anne Manoj Chowdary Vs. Dy. Cit Hyderabad Central Circle 1(4) Pan:Ainpc5963B Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Phaneendra Nag, Ca राज" व "ारा/Revenue By:: Shri Waseem Ur Rehman, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 03/12/2025 घोषणा की तारीख/Pronouncement: 19/12/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

For Appellant: Shri Phaneendra Nag, CAFor Respondent: : Shri Waseem UR Rehman, Sr. DR
Section 115BSection 132Section 132(4)Section 139(1)Section 143(3)Section 271ASection 69A

lakhs, and accordingly directed the Ld. AO to tax the said sum at normal rates. The Ld. AR argued that the levy of penalty under section 271AAB(1A) of the Act presupposes that the income must fall within the definition of “undisclosed income” under clause (c) of the Explanation ... other documents or transactions found during the course of search under section 132 of the Act. Thus, the very foundation for levy of penalty under section 271AAB(1A) of the Act is the existence of incriminating material found during search indicating such income. In the present case, as already recorded

PIYUSH GARG,AHMEDABAD vs. DCIT, CC-1(2), AHMEDABAD

In the result, the appeal of the assessee is dismissed

ITA 1590/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2022-23

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2022-23

For Appellant: Shri Anurag Sinha, A.RFor Respondent: Shri Uday Kishanrao Kakne, Sr. D.R
Section 115BSection 132ASection 143(1)Section 143(3)Section 154Section 271A

appellant, ignoring the material fact that such rectification was undertaken soon after the appellant had successfully demonstrated before the AO that penalty under section 271AAB, as originally initiated, cannot be levied upon the appellant. 6. BECAUSE, the Ld. CIT(A) while upholding the validity of impugned rectification order ignored ... trying to correct non-applicable section but omitting to ignore that the AO has done exactly the same. The AO had initially initiated penalty under section 271AAB (which section is not at all applicable) and upon being objected in writing the AO arbitrarily taking aid of 154, initiated penalty under

TRIJAL ENTERPRISE PRIVATE LIMITED,BHUBANESWAR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2,BHUBANESWAR, BHUBANESWAR

In the result, all the appeals of the assessee are allowed

ITA 263/CTK/2025[2019-20]Status: DisposedITAT Cuttack02 Dec 2025AY 2019-20

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.261, 262 & 263/Ctk/2025 (नििाारण वर्ा / Assessment Year : 2017-18, 2018-19 & 2019-20) Trijal Enterprise Private Limited Vs Acit, Central Circle-2, At-Hall No.6, Block-2, Bmc Bhubaneswar Bhawani Mall, Saheed Nagar, Khordha-751007, Bhubaneswar Pan No. :Aafct 9662 B (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri P.K.Mishra, Ar राजस्व की ओर से /Revenue By : Shri Ashim Kumar Chakraborty, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 02/12/2025 घोषणा की तारीख/Date Of Pronouncement : 02/12/2025 आदेश / O R D E R Per Bench : These Are The Three Appeals Filed By The Assessee Against The Separate Orders Passed By The Ld. Cit(A), Bhubaneswar-2, All Dated 25.03.2025 For The Assessment Years 2017-2018, 2018-2019 & 2019-2020 Confirming The Penalty Levy Under 270A Of The Act. 2. It Was Submitted By The Ld. Ar That For The Impugned Assessment Years The Assessee Has Filed Original Return For The Assessment Year 2017- 18 Disclosing A Loss Of Rs.8,30,930/-, For The Assessment Year 2018-19 Income Of Rs.20,46,140/- & For Assessment Year 2019-20 An Income Of Rs.17,27,850/-. There Was A Search On The Premises Of The Assessee On 03/04/2019. In Response To Notice Issued U/S.153A Of The Act, The Assessee Filed His Return Of Income For The Assessment Year 2017-18 Disclosing A Loss

For Appellant: Shri P.K.Mishra, ARFor Respondent: Shri Ashim Kumar Chakraborty, CIT-DR
Section 139Section 153ASection 270ASection 271A

note that the disclosure of additional income in the statement recorded under section 132(4) Itself is not sufficient to levy the penalty under section 271AAB of the Act until and unless the income so disclosed by the assessee falls in the definition of undisclosed income defined in the explanation ... explanation to the said section. Therefore we do not agree with the contention of the Id. D/R that the levy of penalty under section 271AAB is mandatory simply because the AO has to first issue a show cause notice to the assessee and then has to make a decision

TRIJAL ENTERPRISE PRIVATE LIMITED,BHUBANESWAR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2,BHUBANESWAR, BHUBANESWAR

In the result, all the appeals of the assessee are allowed

ITA 262/CTK/2025[2018-19]Status: DisposedITAT Cuttack02 Dec 2025AY 2018-19

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.261, 262 & 263/Ctk/2025 (नििाारण वर्ा / Assessment Year : 2017-18, 2018-19 & 2019-20) Trijal Enterprise Private Limited Vs Acit, Central Circle-2, At-Hall No.6, Block-2, Bmc Bhubaneswar Bhawani Mall, Saheed Nagar, Khordha-751007, Bhubaneswar Pan No. :Aafct 9662 B (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri P.K.Mishra, Ar राजस्व की ओर से /Revenue By : Shri Ashim Kumar Chakraborty, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 02/12/2025 घोषणा की तारीख/Date Of Pronouncement : 02/12/2025 आदेश / O R D E R Per Bench : These Are The Three Appeals Filed By The Assessee Against The Separate Orders Passed By The Ld. Cit(A), Bhubaneswar-2, All Dated 25.03.2025 For The Assessment Years 2017-2018, 2018-2019 & 2019-2020 Confirming The Penalty Levy Under 270A Of The Act. 2. It Was Submitted By The Ld. Ar That For The Impugned Assessment Years The Assessee Has Filed Original Return For The Assessment Year 2017- 18 Disclosing A Loss Of Rs.8,30,930/-, For The Assessment Year 2018-19 Income Of Rs.20,46,140/- & For Assessment Year 2019-20 An Income Of Rs.17,27,850/-. There Was A Search On The Premises Of The Assessee On 03/04/2019. In Response To Notice Issued U/S.153A Of The Act, The Assessee Filed His Return Of Income For The Assessment Year 2017-18 Disclosing A Loss

For Appellant: Shri P.K.Mishra, ARFor Respondent: Shri Ashim Kumar Chakraborty, CIT-DR
Section 139Section 153ASection 270ASection 271A

note that the disclosure of additional income in the statement recorded under section 132(4) Itself is not sufficient to levy the penalty under section 271AAB of the Act until and unless the income so disclosed by the assessee falls in the definition of undisclosed income defined in the explanation ... explanation to the said section. Therefore we do not agree with the contention of the Id. D/R that the levy of penalty under section 271AAB is mandatory simply because the AO has to first issue a show cause notice to the assessee and then has to make a decision

TRIJAL ENTERPRISE PRIVATE LIMITED,BHUBANESWAR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, BHUBANESWAR, BHUBANESWAR

In the result, all the appeals of the assessee are allowed

ITA 261/CTK/2025[2017-18]Status: DisposedITAT Cuttack02 Dec 2025AY 2017-18

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.261, 262 & 263/Ctk/2025 (नििाारण वर्ा / Assessment Year : 2017-18, 2018-19 & 2019-20) Trijal Enterprise Private Limited Vs Acit, Central Circle-2, At-Hall No.6, Block-2, Bmc Bhubaneswar Bhawani Mall, Saheed Nagar, Khordha-751007, Bhubaneswar Pan No. :Aafct 9662 B (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri P.K.Mishra, Ar राजस्व की ओर से /Revenue By : Shri Ashim Kumar Chakraborty, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 02/12/2025 घोषणा की तारीख/Date Of Pronouncement : 02/12/2025 आदेश / O R D E R Per Bench : These Are The Three Appeals Filed By The Assessee Against The Separate Orders Passed By The Ld. Cit(A), Bhubaneswar-2, All Dated 25.03.2025 For The Assessment Years 2017-2018, 2018-2019 & 2019-2020 Confirming The Penalty Levy Under 270A Of The Act. 2. It Was Submitted By The Ld. Ar That For The Impugned Assessment Years The Assessee Has Filed Original Return For The Assessment Year 2017- 18 Disclosing A Loss Of Rs.8,30,930/-, For The Assessment Year 2018-19 Income Of Rs.20,46,140/- & For Assessment Year 2019-20 An Income Of Rs.17,27,850/-. There Was A Search On The Premises Of The Assessee On 03/04/2019. In Response To Notice Issued U/S.153A Of The Act, The Assessee Filed His Return Of Income For The Assessment Year 2017-18 Disclosing A Loss

For Appellant: Shri P.K.Mishra, ARFor Respondent: Shri Ashim Kumar Chakraborty, CIT-DR
Section 139Section 153ASection 270ASection 271A

note that the disclosure of additional income in the statement recorded under section 132(4) Itself is not sufficient to levy the penalty under section 271AAB of the Act until and unless the income so disclosed by the assessee falls in the definition of undisclosed income defined in the explanation ... explanation to the said section. Therefore we do not agree with the contention of the Id. D/R that the levy of penalty under section 271AAB is mandatory simply because the AO has to first issue a show cause notice to the assessee and then has to make a decision

TRIG DETECTIVES PVT LTD,MUMBAI vs. DCIT-CENTRAL CIRCLE 1(2), MUMBAI

In the result, the appeals filed by the assessee bearing ITA Nos

ITA 1906/MUM/2025[2020-21]Status: DisposedITAT Mumbai02 Dec 2025AY 2020-21

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Rakesh JoshiFor Respondent: Shri Ritesh Misra, CIT DR
Section 139(1)Section 153ASection 250Section 270ASection 271(1)(c)Section 271ASection 274Section 37(1)Section 40

ordinate bench, the penalties levied under section 270A for these years are also liable to be deleted. 10. With respect to penalty under section 271AAB for AY 2020–21, we note that the penalty has been imposed solely on account of disallowances of search. As held in Swaran Nadhan Salaria

TRIG DETECTIVES PVT LTD,MUMBAI vs. DCIT -CENTRAL CIRCLE -1(2), MUMBAI

In the result, the appeals filed by the assessee bearing ITA Nos

ITA 1905/MUM/2025[2019-20]Status: DisposedITAT Mumbai02 Dec 2025AY 2019-20

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Rakesh JoshiFor Respondent: Shri Ritesh Misra, CIT DR
Section 139(1)Section 153ASection 250Section 270ASection 271(1)(c)Section 271ASection 274Section 37(1)Section 40

ordinate bench, the penalties levied under section 270A for these years are also liable to be deleted. 10. With respect to penalty under section 271AAB for AY 2020–21, we note that the penalty has been imposed solely on account of disallowances of search. As held in Swaran Nadhan Salaria

TRIG DETECTIVES PVT LTD,MUMBAI vs. DCIT-CENTRAL CIRCLE 1(2), MUMBAI

In the result, the appeals filed by the assessee bearing ITA Nos

ITA 1904/MUM/2025[2018-19]Status: DisposedITAT Mumbai02 Dec 2025AY 2018-19

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Rakesh JoshiFor Respondent: Shri Ritesh Misra, CIT DR
Section 139(1)Section 153ASection 250Section 270ASection 271(1)(c)Section 271ASection 274Section 37(1)Section 40

ordinate bench, the penalties levied under section 270A for these years are also liable to be deleted. 10. With respect to penalty under section 271AAB for AY 2020–21, we note that the penalty has been imposed solely on account of disallowances of search. As held in Swaran Nadhan Salaria

TRIG DETECTIVES PVT LTD,MUMBAI vs. DCIT-CENTRAL CIRCLE 1(2), MUMBAI

In the result, the appeals filed by the assessee bearing ITA Nos

ITA 1903/MUM/2025[2017-18]Status: DisposedITAT Mumbai02 Dec 2025AY 2017-18

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Rakesh JoshiFor Respondent: Shri Ritesh Misra, CIT DR
Section 139(1)Section 153ASection 250Section 270ASection 271(1)(c)Section 271ASection 274Section 37(1)Section 40

ordinate bench, the penalties levied under section 270A for these years are also liable to be deleted. 10. With respect to penalty under section 271AAB for AY 2020–21, we note that the penalty has been imposed solely on account of disallowances of search. As held in Swaran Nadhan Salaria

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