Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
Impugned order setting aside claim for interest u/s 244A(2) was incorrect. Court held delay attributable to assessee must be excluded for computing interest period, but Department failed to exercise due diligence causing loss to assessee. No straight-jacket formula applies; each case warrants consideration based on facts. Order remanded to Department to reconsider interest claim from date of filing Revision Petition till payment date at 6% per annum after adjusting refund already granted.
Impugned order setting aside claim for interest u/s 244A(2) was incorrect. Court held delay attributable to assessee must be excluded for computing interest period, but Department failed to exercise due diligence causing loss to assessee. No straight-jacket formula applies; each case warrants consideration based on facts. Order remanded to Department to reconsider interest claim from date of filing Revision Petition till payment date at 6% per annum after adjusting refund already granted.
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