Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
Validity of the reassessment order u/s 147 - addition of bogus accommodation entry - AO has not even mentioned as to what was the nature of entry as given in the report and simply saying that assessee received entry (of huge amount) from entry operators during the period is not sufficient. Such a vague reasons cannot justify the reopening and as observed above, the Assessing Officer can validly acquire jurisdiction only when the reasons recorded itself points out or speaks of live link nexus with the material available on record and income escaping assessment and it should not be vague or mere pretence - the reasons recorded does not confer any jurisdiction to him reopen the case - AT
Validity of the reassessment order u/s 147 - addition of bogus accommodation entry - AO has not even mentioned as to what was the nature of entry as given in the report and simply saying that assessee received entry (of huge amount) from entry operators during the period is not sufficient. Such a vague reasons cannot justify the reopening and as observed above, the Assessing Officer can validly acquire jurisdiction only when the reasons recorded itself points out or speaks of live link nexus with the material available on record and income escaping assessment and it should not be vague or mere pretence - the reasons recorded does not confer any jurisdiction to him reopen the case - AT
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