Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
ITAT set aside the assessment order dated 23.02.2024 passed u/s 143(3) r.w.s 254 due to violation of principles of natural justice. The Tribunal directed the Assessing Officer to proceed afresh after providing the assessee with an opportunity to rebut evidence and supplying all adverse reports and documents. The limitation period was found valid under the first proviso to section 153(3), with the assessment order being within the prescribed twelve-month timeframe. The assessee's appeal was allowed for statistical purposes, mandating a de novo proceeding with complete procedural fairness.
ITAT set aside the assessment order dated 23.02.2024 passed u/s 143(3) r.w.s 254 due to violation of principles of natural justice. The Tribunal directed the Assessing Officer to proceed afresh after providing the assessee with an opportunity to rebut evidence and supplying all adverse reports and documents. The limitation period was found valid under the first proviso to section 153(3), with the assessment order being within the prescribed twelve-month timeframe. The assessee's appeal was allowed for statistical purposes, mandating a de novo proceeding with complete procedural fairness.
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