Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
The ITAT held that the final assessment order passed under section 143(3) read with section 144C(13) was time-barred. The AO was required to complete the assessment within one month from the end of the month in which directions were received from the DRP. Since the DRP issued directions on 21.09.2021, the assessment should have been completed by 31.10.2021. However, the AO passed the final order on 18.11.2021, beyond the prescribed period. Consequently, the tribunal quashed the assessment order as void ab initio for non-compliance with the statutory time limit, allowing the appeal.
The ITAT held that the final assessment order passed under section 143(3) read with section 144C(13) was time-barred. The AO was required to complete the assessment within one month from the end of the month in which directions were received from the DRP. Since the DRP issued directions on 21.09.2021, the assessment should have been completed by 31.10.2021. However, the AO passed the final order on 18.11.2021, beyond the prescribed period. Consequently, the tribunal quashed the assessment order as void ab initio for non-compliance with the statutory time limit, allowing the appeal.
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