Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
HC affirmed the reopening of assessment under Section 147, validating the Assessing Officer's objective satisfaction regarding income escaping assessment. The assessee, represented by a chartered accountant, failed to provide explanations or substantiate the genuineness of transactions involving penny stocks and a shell company. The court found the AO's reasons for reassessment were not vague and demonstrated due diligence. The Appellate Authority's rejection of the assessee's appeal and the lack of credible evidence supporting the transaction's legitimacy led to the decision being rendered in favor of the revenue.
HC affirmed the reopening of assessment under Section 147, validating the Assessing Officer's objective satisfaction regarding income escaping assessment. The assessee, represented by a chartered accountant, failed to provide explanations or substantiate the genuineness of transactions involving penny stocks and a shell company. The court found the AO's reasons for reassessment were not vague and demonstrated due diligence. The Appellate Authority's rejection of the assessee's appeal and the lack of credible evidence supporting the transaction's legitimacy led to the decision being rendered in favor of the revenue.
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