Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
Revision u/s 263 - AO did not initiate penalty proceedings u/s. 271(1) (c) - No hesitation in holding that the CIT is not correct in assuming jurisdiction u/s 263 of the income tax act where the learned assessing officer has failed to initiate penalty proceedings and also does not record any satisfaction of furnishing of inaccurate particulars or concealment of income in the assessment order. - AT
Revision u/s 263 - AO did not initiate penalty proceedings u/s. 271(1) (c) - No hesitation in holding that the CIT is not correct in assuming jurisdiction u/s 263 of the income tax act where the learned assessing officer has failed to initiate penalty proceedings and also does not record any satisfaction of furnishing of inaccurate particulars or concealment of income in the assessment order. - AT
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