Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
Alternative statutory remedy and unexplained delay barred writ review of customs confiscation adjudication, leaving merits for appellate consideration...
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Revisionary jurisdiction requires both an erroneous assessment order and prejudice to Revenue. It cannot be exercised merely because the revisionary authority considers that the Assessing Officer should have made further or different inquiries. Where the assessee disclosed material supporting indexed cost of acquisition and cost of improvement, and the Assessing Officer considered the explanation before accepting the claim, the assessment reflects a conscious view. Revision cannot therefore substitute the revisionary authority's opinion for the Assessing Officer's considered decision on the disclosed material.
Revisionary jurisdiction requires both an erroneous assessment order and prejudice to Revenue. It cannot be exercised merely because the revisionary authority considers that the Assessing Officer should have made further or different inquiries. Where the assessee disclosed material supporting indexed cost of acquisition and cost of improvement, and the Assessing Officer considered the explanation before accepting the claim, the assessment reflects a conscious view. Revision cannot therefore substitute the revisionary authority's opinion for the Assessing Officer's considered decision on the disclosed material.
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