Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
The Appellate Tribunal (ITAT) considered the validity of proceedings u/s 153C, focusing on whether the satisfaction note recorded by the AO of the searched person was present. The AO stated that the additions to the assessee's income were not based on incriminating material and did not hold up. Additionally, the AO planned to initiate proceedings u/s 148 following the prescribed procedure u/s 148A. As the Revenue acknowledged the lack of incriminating material and initiated proceedings u/s 148, the appeals challenging the additions u/s 153C were upheld, resulting in the assessee's appeal being allowed.
The Appellate Tribunal (ITAT) considered the validity of proceedings u/s 153C, focusing on whether the satisfaction note recorded by the AO of the searched person was present. The AO stated that the additions to the assessee's income were not based on incriminating material and did not hold up. Additionally, the AO planned to initiate proceedings u/s 148 following the prescribed procedure u/s 148A. As the Revenue acknowledged the lack of incriminating material and initiated proceedings u/s 148, the appeals challenging the additions u/s 153C were upheld, resulting in the assessee's appeal being allowed.
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