Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Penalty for non-disclosure of foreign assets was not sustained where the assessee disclosed the assets and foreign income in the return filed after search, and that return operated as the substituted return in place of the original return. Because the Revenue accepted the disclosure, made no addition in the assessment framed on the later return, and produced no material showing deliberate tax evasion, the earlier omission from the original return was treated as a bona fide technical lapse. On those facts, deletion of penalty under the Black Money Act was upheld.
Penalty for non-disclosure of foreign assets was not sustained where the assessee disclosed the assets and foreign income in the return filed after search, and that return operated as the substituted return in place of the original return. Because the Revenue accepted the disclosure, made no addition in the assessment framed on the later return, and produced no material showing deliberate tax evasion, the earlier omission from the original return was treated as a bona fide technical lapse. On those facts, deletion of penalty under the Black Money Act was upheld.
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