Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
ITAT ruled in favor of the assessee, setting aside the Pr. CIT's order under Section 263. The tribunal found that the Assessing Officer (AO) had conducted a proper inquiry and accepted the assessee's documentary evidence regarding the land's distance from municipal limits. The Pr. CIT's attempt to reexamine the issue based on a 2024 Google map verification was deemed inappropriate, particularly given municipal limit changes in 2016. The tribunal emphasized that when the AO has already satisfied himself with the supporting evidence, the CIT cannot remand the matter for fresh adjudication merely due to uncertainty about the claim's correctness.
ITAT ruled in favor of the assessee, setting aside the Pr. CIT's order under Section 263. The tribunal found that the Assessing Officer (AO) had conducted a proper inquiry and accepted the assessee's documentary evidence regarding the land's distance from municipal limits. The Pr. CIT's attempt to reexamine the issue based on a 2024 Google map verification was deemed inappropriate, particularly given municipal limit changes in 2016. The tribunal emphasized that when the AO has already satisfied himself with the supporting evidence, the CIT cannot remand the matter for fresh adjudication merely due to uncertainty about the claim's correctness.
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