Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
ITAT reversed CIT(A)'s deletion of penalty under s271AAB imposed during search and seizure proceedings. The company director had declared undisclosed income, but CIT(A) deleted penalty citing vague show cause notices. ITAT found AO had clearly specified penalty charges under s271AAB(1A) in both assessment and penalty orders, properly notifying assessee of proceedings and undisclosed amount. Computer-generated notice limitations were acknowledged. Following precedents from Allahabad HC and ITAT Pune, tribunal held CIT(A)'s order unsustainable, reinstating penalty. Revenue's appeal allowed, emphasizing sufficient specification of charges despite standardized notice format.
ITAT reversed CIT(A)'s deletion of penalty under s271AAB imposed during search and seizure proceedings. The company director had declared undisclosed income, but CIT(A) deleted penalty citing vague show cause notices. ITAT found AO had clearly specified penalty charges under s271AAB(1A) in both assessment and penalty orders, properly notifying assessee of proceedings and undisclosed amount. Computer-generated notice limitations were acknowledged. Following precedents from Allahabad HC and ITAT Pune, tribunal held CIT(A)'s order unsustainable, reinstating penalty. Revenue's appeal allowed, emphasizing sufficient specification of charges despite standardized notice format.
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