Sec. 271AAA of Income-tax Act, 1961— Penalty— The date of filing the return of income under s. 139(1)  has expired on 31st Oct., 2007 and much after; the Department initiated the search action under s. 132 on 10th Jan., 2008, in view of the provisions of section 139(1), the previous year had ended before the date of search and the date of filing of return of income under s. 139(1) had also been expired, thus, the provisions of s. 271AAA  have no application in this case, and accordingly, the ground raised by the assessee to this extent is allowed. There was non-compliance of provisions of TDS in respect of land development expenses incurred by way of payment made, but not deducted TDS, moreover, while filing return under s. 153A, the assessee has failed to add the statutory disallowances applicable as per law, thereby the assessee has furnished inaccurate particulars warranting levy of penalty, thus, the AO has rightly levied penalty under s. 271(1)(c) and the same stands confirmed — S & P Foundations (P) Ltd. vs. Asstt. CIT [2020] 203 TTJ 650 (CHENNAI)