Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
HC quashed the assessment order u/s 143(3) after determining AO's lack of inherent jurisdiction. The Tribunal analyzed the case facts, noting the assessee's nil income return and subsequent notices u/s 143(2) and 142(1). Relying on CBDT Instruction No.1 of 2011 and precedent in Bhagyalaxmi Conclave (P) Ltd., the Tribunal found the AO exceeded jurisdictional limits. The revenue's challenge was unsuccessful, with the HC dismissing a similar appeal involving identical substantial legal questions. Consequently, the Tribunal's order setting aside the AO's assessment was upheld, effectively deciding against the revenue on jurisdictional grounds.
HC quashed the assessment order u/s 143(3) after determining AO's lack of inherent jurisdiction. The Tribunal analyzed the case facts, noting the assessee's nil income return and subsequent notices u/s 143(2) and 142(1). Relying on CBDT Instruction No.1 of 2011 and precedent in Bhagyalaxmi Conclave (P) Ltd., the Tribunal found the AO exceeded jurisdictional limits. The revenue's challenge was unsuccessful, with the HC dismissing a similar appeal involving identical substantial legal questions. Consequently, the Tribunal's order setting aside the AO's assessment was upheld, effectively deciding against the revenue on jurisdictional grounds.
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