Tribunal held that since the search was initiated against the assessee on 7th Nov., 2019, the AO did not have jurisdiction to issue notice under s. 271AAB(1); AO ought to have issued under sub-s. (1A) of s. 271AAB and also mentioned the specific limb cl. (a) or cl. (b) of s. 271AAB(1A) under which the assessee is being proceeded against for the levy of a penalty. AO having wrongly issued notice under s. 271AAB(1), the entire penalty proceedings are ab initio void and, therefore, quashed. (AY. 2018-19, 2020-21)
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