Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
Validity of Reopening of assessment - A receipt of some information from another wing of the Department cannot be equated with a realization of escapement per se. Such information/evidence can possibly give birth to realization or belief of the AO as contemplated under section 147 of the Act. However, an independent formation of belief thereon is sine qua non for taking action under section 147 of the Act. - AT
Validity of Reopening of assessment - A receipt of some information from another wing of the Department cannot be equated with a realization of escapement per se. Such information/evidence can possibly give birth to realization or belief of the AO as contemplated under section 147 of the Act. However, an independent formation of belief thereon is sine qua non for taking action under section 147 of the Act. - AT
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