Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
Assessee failed to justify receipt discrepancy between ITR and Form 26AS, AO made addition considering it as fees for technical services and imposed penalty u/s 270A for under-reporting income. ITAT held penalty order silent on assessee's submissions, penalty notice lacked specific allegation of misrepresentation/suppression, and subsequent rectification of Form 26AS removed discrepancy. Relying on Supreme Court judgment, ITAT set aside penalty considering entirety of circumstances and allowed assessee's grounds.
Assessee failed to justify receipt discrepancy between ITR and Form 26AS, AO made addition considering it as fees for technical services and imposed penalty u/s 270A for under-reporting income. ITAT held penalty order silent on assessee's submissions, penalty notice lacked specific allegation of misrepresentation/suppression, and subsequent rectification of Form 26AS removed discrepancy. Relying on Supreme Court judgment, ITAT set aside penalty considering entirety of circumstances and allowed assessee's grounds.
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