Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
Validity of re-assessment proceedings initiated u/s.148 - If the reasons recorded are silent or there is no reference of any material, then other extraneous material referred subsequently cannot justify acquiring of jurisdiction for reopening u/s 147. Any annexure or report discussed in the assessment order which is not part of the reasons recorded cannot be construed as material forming belief u/s.147. - The reasons recorded itself goes to show that it is purely based on borrowed satisfaction and without application of mind - AT
Validity of re-assessment proceedings initiated u/s.148 - If the reasons recorded are silent or there is no reference of any material, then other extraneous material referred subsequently cannot justify acquiring of jurisdiction for reopening u/s 147. Any annexure or report discussed in the assessment order which is not part of the reasons recorded cannot be construed as material forming belief u/s.147. - The reasons recorded itself goes to show that it is purely based on borrowed satisfaction and without application of mind - AT
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