Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
HC held that Form 26AS with apparent errors cannot constitute tangible material for reopening assessment. The assessment order was invalid as duplicate entries in Form 26AS showed only a minimal discrepancy of Rs. 1,926/- in salary income. The revenue's argument regarding extended limitation period was rejected. The AO lacked sufficient grounds to believe income had escaped assessment. Appellate authorities CIT(A) and ITAT concurred that the reassessment was unsustainable. The court ultimately decided in favor of the assessee, nullifying the reassessment proceedings due to lack of substantive evidence of income escapement.
HC held that Form 26AS with apparent errors cannot constitute tangible material for reopening assessment. The assessment order was invalid as duplicate entries in Form 26AS showed only a minimal discrepancy of Rs. 1,926/- in salary income. The revenue's argument regarding extended limitation period was rejected. The AO lacked sufficient grounds to believe income had escaped assessment. Appellate authorities CIT(A) and ITAT concurred that the reassessment was unsustainable. The court ultimately decided in favor of the assessee, nullifying the reassessment proceedings due to lack of substantive evidence of income escapement.
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