Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
ITAT invalidated reassessment proceedings initiated beyond four years, finding no new substantive evidence to justify reopening. The Tribunal determined that the Assessing Officer's attempt to reopen the case was merely a change of opinion on existing facts, without discovering any fresh information. The assessee had previously disclosed all relevant details during original assessment proceedings, including land sale particulars in audited financial statements. Consequently, the Tribunal quashed the notice under Section 148 and the subsequent reassessment order, thereby allowing the assessee's appeal and rendering the reopening proceedings legally unsustainable.
ITAT invalidated reassessment proceedings initiated beyond four years, finding no new substantive evidence to justify reopening. The Tribunal determined that the Assessing Officer's attempt to reopen the case was merely a change of opinion on existing facts, without discovering any fresh information. The assessee had previously disclosed all relevant details during original assessment proceedings, including land sale particulars in audited financial statements. Consequently, the Tribunal quashed the notice under Section 148 and the subsequent reassessment order, thereby allowing the assessee's appeal and rendering the reopening proceedings legally unsustainable.
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