Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
The ITAT upheld the Assessing Officer's determination that the actual sale consideration for the immovable property was Rs. 5,04,80,000/-, rejecting the assessee's arrangement with True Value as a sham transaction designed to divert sale proceeds and reduce tax liability. True Value was neither the property owner nor the assessee's authorized agent, and the claimed 50% commission was unjustified. The Tribunal confirmed the reduction of the sale consideration from WDV of the block of assets and the consequent disallowance of excess depreciation of Rs. 25,48,000/-. However, the separate addition of Rs. 2.54 Crores for disallowance of expenditure was deleted as Revenue failed to establish that this amount was separately debited in the assessee's P&L account. The Revenue's appeal was partly allowed.
The ITAT upheld the Assessing Officer's determination that the actual sale consideration for the immovable property was Rs. 5,04,80,000/-, rejecting the assessee's arrangement with True Value as a sham transaction designed to divert sale proceeds and reduce tax liability. True Value was neither the property owner nor the assessee's authorized agent, and the claimed 50% commission was unjustified. The Tribunal confirmed the reduction of the sale consideration from WDV of the block of assets and the consequent disallowance of excess depreciation of Rs. 25,48,000/-. However, the separate addition of Rs. 2.54 Crores for disallowance of expenditure was deleted as Revenue failed to establish that this amount was separately debited in the assessee's P&L account. The Revenue's appeal was partly allowed.
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