Section 271AAB, 153C of Income Tax Act, 1961—In the instant case, various addition were made to the total income of the assessee in the order passed u/s. 153C of the Act r.w.s. 143(3) of the Act.  In respect of those additions, penalty proceedings were initiated u/s. 271AAB of the Act.

Held that—we are of the view that the penalty in the case of assessee cannot be sustained as the assessee was not a person who was subjected to search u/s. 132 of the Act and consequently the provisions of section 271AAB could not be invoked in his case. [SHRI SURESH H. KERUDI VERSUS THE INCOME TAX OFFICER, WARD-1, BAGALKOT.][2019] 18 ITCD Online (14) [ ITAT BANGALORE]