In the result, the assessee’s appeal is allowed
Bench: Sh. Sanjay Arora & Sh. N. K. Choudhryi. T. A. No. 458/(Asr)/2017 Assessment Year: 2010-11
section 271(1)(c), alluded to by the ld. CIT(A), is not applicable as the search was after 31.05.2007, and even as observed during hearing, that would be wholly inconsequential as Explanation 5A, a pari materia provision, applicable to searches after 31.05.2007, would stand attracted, which in fact is more stringent than Explanation 5. Being a part