Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
The ITAT dismissed the Revenue's quantum appeal. It upheld the CIT(A)'s finding that the unexplained cash found during search was part of the income surrendered by the assessee u/s 132(4), based on the statement recorded. Regarding the penalty u/s 271AAB(1)(a), the ITAT deleted it on technical grounds, as the penalty notice did not specify clear charges against the assessee for not fulfilling the conditions and not divulging the source of income, violating natural justice principles.
The ITAT dismissed the Revenue's quantum appeal. It upheld the CIT(A)'s finding that the unexplained cash found during search was part of the income surrendered by the assessee u/s 132(4), based on the statement recorded. Regarding the penalty u/s 271AAB(1)(a), the ITAT deleted it on technical grounds, as the penalty notice did not specify clear charges against the assessee for not fulfilling the conditions and not divulging the source of income, violating natural justice principles.
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