Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
ITAT set aside CIT(A)'s order regarding exemption u/s 10(26AAA) for Sikkimese individual's income. CIT(A) had deleted additions u/ss 69A and 69 based solely on identification certificate without following Rule 46A(3) of IT Rules, which requires AO verification. ITAT restored assessment proceedings before AO for fresh consideration, allowing assessee opportunity to present evidence supporting exemption claim. Both Revenue's counsel and assessee's representative agreed to this approach. Revenue's appeal allowed for statistical purposes. Matter remanded for verification of whether conditions u/s 10(26AAA) were fulfilled, ensuring procedural compliance and fair hearing.
ITAT set aside CIT(A)'s order regarding exemption u/s 10(26AAA) for Sikkimese individual's income. CIT(A) had deleted additions u/ss 69A and 69 based solely on identification certificate without following Rule 46A(3) of IT Rules, which requires AO verification. ITAT restored assessment proceedings before AO for fresh consideration, allowing assessee opportunity to present evidence supporting exemption claim. Both Revenue's counsel and assessee's representative agreed to this approach. Revenue's appeal allowed for statistical purposes. Matter remanded for verification of whether conditions u/s 10(26AAA) were fulfilled, ensuring procedural compliance and fair hearing.
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