Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
Reassessment beyond three years requires escaped income to meet the statutory threshold; where unaccounted purchases had corresponding sales and the embedded profit was separately assessed, only that profit constituted escaped income. Reassessment notices for AY 2014-15 to AY 2018-19 were therefore quashed. Material seized during a third-party search required notice under section 148 before assessment, rendering the direct AY 2022-23 assessment void. No cross-examination breach arose without a specific request, and the pre-amendment reassessment regime permitted a 30-day return period. Where corresponding sales were accepted, tax applied only to embedded profit, not the full unaccounted purchase value.
Reassessment beyond three years requires escaped income to meet the statutory threshold; where unaccounted purchases had corresponding sales and the embedded profit was separately assessed, only that profit constituted escaped income. Reassessment notices for AY 2014-15 to AY 2018-19 were therefore quashed. Material seized during a third-party search required notice under section 148 before assessment, rendering the direct AY 2022-23 assessment void. No cross-examination breach arose without a specific request, and the pre-amendment reassessment regime permitted a 30-day return period. Where corresponding sales were accepted, tax applied only to embedded profit, not the full unaccounted purchase value.
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