Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
HC held that Section 154's rectification scope extends to legitimate claims omitted from income tax returns, rejecting the tribunal's narrow interpretation. The court determined that 'record' under Section 154 encompasses financial statements and books of accounts across assessment years, not limited to the specific year under review. Upon verification of ledger accounts demonstrating payment of Rs. 95,36,264/- (including Rs. 65,22,000/- on 20.11.1997), the HC overturned the tribunal's order. The court emphasized that mechanical objections should not defeat Section 154's remedial purpose and confirmed the assessee's right to claim previously omitted surcharge payments through rectification proceedings, even when such claims were not included in the original return.
HC held that Section 154's rectification scope extends to legitimate claims omitted from income tax returns, rejecting the tribunal's narrow interpretation. The court determined that 'record' under Section 154 encompasses financial statements and books of accounts across assessment years, not limited to the specific year under review. Upon verification of ledger accounts demonstrating payment of Rs. 95,36,264/- (including Rs. 65,22,000/- on 20.11.1997), the HC overturned the tribunal's order. The court emphasized that mechanical objections should not defeat Section 154's remedial purpose and confirmed the assessee's right to claim previously omitted surcharge payments through rectification proceedings, even when such claims were not included in the original return.
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