Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
Non-issue of legally valid notice u/s. 143(2) - Whether it is a curable defect? - Section 124(3) of the Act does not in any way help the Department to justify the action of AO at Shillong in issuing notice under Section 143(2) to the assessee, which is an action done by him without jurisdiction. - Since in the present case no valid notice u/s 143(2) was issued by the AO who held jurisdiction over the case of the appellant, the consequent order passed u/s 143(3) dated 24.03.2014 was legally unsustainable and therefore is null in the eyes of law and therefore quashed. - AT
Non-issue of legally valid notice u/s. 143(2) - Whether it is a curable defect? - Section 124(3) of the Act does not in any way help the Department to justify the action of AO at Shillong in issuing notice under Section 143(2) to the assessee, which is an action done by him without jurisdiction. - Since in the present case no valid notice u/s 143(2) was issued by the AO who held jurisdiction over the case of the appellant, the consequent order passed u/s 143(3) dated 24.03.2014 was legally unsustainable and therefore is null in the eyes of law and therefore quashed. - AT
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