Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
Penalty u/s 271(1)(C) - Unexplained Expenditure on Stamp Duty and Registration Charges made out of Undisclosed Income - There was no dishonest intent of the assessee particularly in the given facts and circumstances where the assessee had sufficient income i.e. exceeding the amount invested in purchases of properties. Accordingly, we are of the view that the assessee inadvertently omitted to disclose the impugned cost in the income tax return without having any dishonest intent. Thus in such facts and circumstances, we hold that the penalty u/s 271(1)(c) of the Act, is not sustainable. - AT
Penalty u/s 271(1)(C) - Unexplained Expenditure on Stamp Duty and Registration Charges made out of Undisclosed Income - There was no dishonest intent of the assessee particularly in the given facts and circumstances where the assessee had sufficient income i.e. exceeding the amount invested in purchases of properties. Accordingly, we are of the view that the assessee inadvertently omitted to disclose the impugned cost in the income tax return without having any dishonest intent. Thus in such facts and circumstances, we hold that the penalty u/s 271(1)(c) of the Act, is not sustainable. - AT
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