Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
AO's jurisdiction was challenged regarding notice u/s 143(2) after territorial reassignment. ITAT determined that jurisdictional challenges fall under Part B, Chapter XIII, requiring administrative consideration first. Neither ITO nor ACIT lacked territorial jurisdiction; the change merely reflected pecuniary jurisdiction under s.120(3). Following precedents from Kalinga Institute and Mantoo Sarkar cases, ITAT ruled pecuniary jurisdiction challenge as untimely and curable. Regarding sundry creditors, CIT(A)'s enhancement under s.41(1) was found procedurally flawed. Matter remanded to AO for determining creditors' genuineness and appropriate year-wise additions, subject to statutory limitations. Assessee directed to furnish complete documentation for accurate assessment.
AO's jurisdiction was challenged regarding notice u/s 143(2) after territorial reassignment. ITAT determined that jurisdictional challenges fall under Part B, Chapter XIII, requiring administrative consideration first. Neither ITO nor ACIT lacked territorial jurisdiction; the change merely reflected pecuniary jurisdiction under s.120(3). Following precedents from Kalinga Institute and Mantoo Sarkar cases, ITAT ruled pecuniary jurisdiction challenge as untimely and curable. Regarding sundry creditors, CIT(A)'s enhancement under s.41(1) was found procedurally flawed. Matter remanded to AO for determining creditors' genuineness and appropriate year-wise additions, subject to statutory limitations. Assessee directed to furnish complete documentation for accurate assessment.
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