Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
The ITAT dismissed the Revenue's appeal and upheld the CIT(A)'s order deleting the addition of Rs. 4 crores u/s 69C. The assessee's books reflected outstanding trade payables to Shri Paranthaman concerns. The seized material and the director's statement were rebutted by the evidence. The ITAT found contradictions and logical flaws in the director's statement relied upon by the AO. The loose sheets did not contain the complete creditors' list and were for reconciliation purposes during account finalization. The assessee established the outstanding trade creditors were allowable and not outside the books.
The ITAT dismissed the Revenue's appeal and upheld the CIT(A)'s order deleting the addition of Rs. 4 crores u/s 69C. The assessee's books reflected outstanding trade payables to Shri Paranthaman concerns. The seized material and the director's statement were rebutted by the evidence. The ITAT found contradictions and logical flaws in the director's statement relied upon by the AO. The loose sheets did not contain the complete creditors' list and were for reconciliation purposes during account finalization. The assessee established the outstanding trade creditors were allowable and not outside the books.
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