Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
The ITAT dismissed the revenue's miscellaneous application challenging the penalty under section 271(1)(c) due to the absence of valid proof of approval from the JCIT for imposing the penalty. The revenue failed to produce a duly signed approval document, presenting only unsigned copies dated 17/03/2020, which were rejected based on established precedent requiring signed authorization before issuance. Consequently, without valid approval evidence, the penalty order lacked procedural compliance, leading to the dismissal of the application.
The ITAT dismissed the revenue's miscellaneous application challenging the penalty under section 271(1)(c) due to the absence of valid proof of approval from the JCIT for imposing the penalty. The revenue failed to produce a duly signed approval document, presenting only unsigned copies dated 17/03/2020, which were rejected based on established precedent requiring signed authorization before issuance. Consequently, without valid approval evidence, the penalty order lacked procedural compliance, leading to the dismissal of the application.
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