Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
Protective addition made in the hands of the assessee - income surrendered by the assessee in the sworn statement - the surrender was not blanket surrender as presumed by the tax authorities. We also noticed that the surrender was couched with various caveats. In any case, the surrender of income without any basis is against the circular issued by CBDT . We also noticed that the assessee has explained later before the AO that the capital gain was in his mind while making surrender. - Additions deleted - AT
Protective addition made in the hands of the assessee - income surrendered by the assessee in the sworn statement - the surrender was not blanket surrender as presumed by the tax authorities. We also noticed that the surrender was couched with various caveats. In any case, the surrender of income without any basis is against the circular issued by CBDT . We also noticed that the assessee has explained later before the AO that the capital gain was in his mind while making surrender. - Additions deleted - AT
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