BHAGYA KALITA,GUWAHATI vs. ACIT, CENTRAL CIRCLE-1, GUWAHATI

In the result, both the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Manomohan Das & Shri Rakesh Mishra

2) are specified, have held that penalty under sub-section (1) of section 271AAA of the Act was not attracted on the said amount. However, there is no such exclusionary provision mentioned in section 271AAB of the Act so as to exclude the imposition of penalty upon certain conditions being fulfilled. Hence, he emphasised that the decision relied upon being