Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
The ITAT upheld the disallowance of deduction under Section 80IB(10) for the relevant assessment year, rejecting the assessee's contention that the allowability determined for a prior year should apply by res judicata. The Tribunal affirmed that principles of res judicata do not apply across different assessment years, as each year is a separate unit of assessment subject to independent scrutiny. The assessee's claim based on a purported timely completion certificate was found to be incorrect, and since the certificate was issued beyond the prescribed completion period, the deduction was rightly denied. The decision of the CIT(Appeals) was confirmed, and the appeal was dismissed.
The ITAT upheld the disallowance of deduction under Section 80IB(10) for the relevant assessment year, rejecting the assessee's contention that the allowability determined for a prior year should apply by res judicata. The Tribunal affirmed that principles of res judicata do not apply across different assessment years, as each year is a separate unit of assessment subject to independent scrutiny. The assessee's claim based on a purported timely completion certificate was found to be incorrect, and since the certificate was issued beyond the prescribed completion period, the deduction was rightly denied. The decision of the CIT(Appeals) was confirmed, and the appeal was dismissed.
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