Previous year ended before date of search and the date of filing pf return of income u/s 139(1) had also been expired, penalty cannot be levied (AY. 2007-08)
S & P Foundations (P) Ltd. v. ACIT (2020) 186 DTR 122 / 203 TTJ 650(Chennai) (Trib.)
S. 271AAA : Penalty-Search initiated on or after 1st June, 2007–Previous year ended before date of search and the date of filing pf return of income u/s. 139(1) had also been expired–Penalty cannot be levied. [S. 139(1)]