Dismissing the appeal the Court held that there was no substantial difference between section 271AAA and section 271AAB of the Act, except that section 271AAA would apply in cases where search has been initiated under section 132 on or after the first day of June 2007 but before the first day of July 2012, whereas section 271AAB would apply in cases where search has been initiated under section 132 on or after the first day of July 2012. The notice and the order of penalty were valid.
Ramgopal Ochhavlal Maheshwari. v. DCIT (2019) 417 ITR 710/ (2020) 187 DTR 417/ 315 CTR 458 (Guj)(HC)
S. 271AAA : Penalty – Search initiated on or after 1st June, 2007 – Notice issued u/s 271AAA and subsequent corrigendum issued stating that notice was u/s 271AAB – Notice and subsequent levy of penalty is held to be valid .[ S. 132 ,271AAB ]