YASH KUMAR GOYAL,GWALIOR vs. DCIT/ACIT 2(1), GWALIOR, GWALIOR
In the result, both appeals filed by the assessee are allowed
ITA 518/AGR/2025[2012-13]Status: DisposedITAT Agra19 Feb 2026AY 2012-13
Bench: : Shri S. Rifaur Rahman
Section 143(3)Section 147Section 148Section 153ASection 153CSection 271(1)(c)Section 274Section 50C
153C, the Assessing Officer cannot make additions based on the original reasons recorded under Section 147/148 unless they are supported by incriminating material found during the search.
4. That the penalty proceedings initiated under Section 271(1)(c) are invalid and unsustainable in law as the Assessing Officer failed to specify in the notice under Section 274 whether the penalty
