Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
HC held that the Assessment Order u/s 147 was void ab initio as the Assessing Officer (AO) lacked tangible material to form a valid belief of income escapement. The AO failed to provide specific details or undertake additional enquiries beyond the original assessment proceedings. The ITAT affirmed that the assessee had fully disclosed material facts, including share applicants' details, PAN, and ITRs, demonstrating creditworthiness. Consequently, the reassessment notice was quashed, and the order was decided in favor of the assessee, emphasizing the need for concrete evidence to initiate reassessment proceedings.
HC held that the Assessment Order u/s 147 was void ab initio as the Assessing Officer (AO) lacked tangible material to form a valid belief of income escapement. The AO failed to provide specific details or undertake additional enquiries beyond the original assessment proceedings. The ITAT affirmed that the assessee had fully disclosed material facts, including share applicants' details, PAN, and ITRs, demonstrating creditworthiness. Consequently, the reassessment notice was quashed, and the order was decided in favor of the assessee, emphasizing the need for concrete evidence to initiate reassessment proceedings.
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