Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
AO failed to examine details, relied solely on assessee's submissions, resulting in erroneous assessment prejudicial to Revenue's interests. Assessee borrowed substantial loans, advanced funds, sold shares with profits, received interest income. AO neglected scrutinizing reasons for borrowings, fund utilization, interest receipts, share sale profits' nature. Invoking section 263 justified as AO's order erroneous, prejudicing Revenue's interests due to inadequate examination.
AO failed to examine details, relied solely on assessee's submissions, resulting in erroneous assessment prejudicial to Revenue's interests. Assessee borrowed substantial loans, advanced funds, sold shares with profits, received interest income. AO neglected scrutinizing reasons for borrowings, fund utilization, interest receipts, share sale profits' nature. Invoking section 263 justified as AO's order erroneous, prejudicing Revenue's interests due to inadequate examination.
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