Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
The HC quashed the reopening of assessment u/s 147, holding that the AO did not apply independent mind and relied solely on borrowed satisfaction from information on the insight portal without verifying material facts. The petitioner had disclosed share transactions through contract notes, ledger, and bank statements. The AO failed to form reasonable belief of income escapement as the disclosed profits were already offered to tax and accepted in regular assessment. Mere information from the insight portal, without examining assessee's records, cannot be a valid reason to believe income has escaped assessment.
The HC quashed the reopening of assessment u/s 147, holding that the AO did not apply independent mind and relied solely on borrowed satisfaction from information on the insight portal without verifying material facts. The petitioner had disclosed share transactions through contract notes, ledger, and bank statements. The AO failed to form reasonable belief of income escapement as the disclosed profits were already offered to tax and accepted in regular assessment. Mere information from the insight portal, without examining assessee's records, cannot be a valid reason to believe income has escaped assessment.
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