Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
Reopening of assessment - non-application of mind by AO - Borrowed satisfaction - Reliance on investigation initiated by Directorate General of Goods and Services Tax (“DG GST”) - The court observed that both the AO and the PCIT failed to properly assess the information and circumstances before approving the reopening notice. They did not adequately verify the petitioner's compliance with disclosure requirements or consider the timing constraints for issuing such notices. This lack of diligence amounted to a total non-application of mind, rendering the approval and subsequent proceedings unsustainable.
Reopening of assessment - non-application of mind by AO - Borrowed satisfaction - Reliance on investigation initiated by Directorate General of Goods and Services Tax (“DG GST”) - The court observed that both the AO and the PCIT failed to properly assess the information and circumstances before approving the reopening notice. They did not adequately verify the petitioner's compliance with disclosure requirements or consider the timing constraints for issuing such notices. This lack of diligence amounted to a total non-application of mind, rendering the approval and subsequent proceedings unsustainable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4827 
Join Channel 
