Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
HC adjudicated reassessment proceedings challenging tax notice under Section 148, determining that conditions in Section 149(1A) were not satisfied. The court interpreted the statutory threshold of Rs. 50 lakhs escaped income, clarifying that cumulative income from multiple assessment years can be considered, but must be represented through a specific asset or expenditure related to a singular event or occasion. The court ultimately allowed the petition and set aside the reassessment proceedings, emphasizing strict compliance with procedural limitations in tax reassessment mechanisms.
HC adjudicated reassessment proceedings challenging tax notice under Section 148, determining that conditions in Section 149(1A) were not satisfied. The court interpreted the statutory threshold of Rs. 50 lakhs escaped income, clarifying that cumulative income from multiple assessment years can be considered, but must be represented through a specific asset or expenditure related to a singular event or occasion. The court ultimately allowed the petition and set aside the reassessment proceedings, emphasizing strict compliance with procedural limitations in tax reassessment mechanisms.
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