Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
HC dismissed the writ petition challenging the assessment order. The key legal determination centered on the precise date of communication of Dispute Resolution Panel (DRP) proceedings under Section 144C(13) of Income Tax Act. The court found that the DRP proceedings dated 10.06.2022 were communicated to the National Faceless Assessment Centre on 22.06.2022 and subsequently transmitted to the Jurisdictional Assessing Officer on 04.07.2022. Consequently, the assessment order passed on 19.08.2022 was within the prescribed limitation period, rendering the petitioner's limitation challenge unsustainable.
HC dismissed the writ petition challenging the assessment order. The key legal determination centered on the precise date of communication of Dispute Resolution Panel (DRP) proceedings under Section 144C(13) of Income Tax Act. The court found that the DRP proceedings dated 10.06.2022 were communicated to the National Faceless Assessment Centre on 22.06.2022 and subsequently transmitted to the Jurisdictional Assessing Officer on 04.07.2022. Consequently, the assessment order passed on 19.08.2022 was within the prescribed limitation period, rendering the petitioner's limitation challenge unsustainable.
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