Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
The HC held that the absence of a DIN on the assessment order, a fundamental issue affecting its validity, was not addressed in the impugned ITAT orders. This omission goes to the root of the assessment's legality and must be considered during appeal disposal. The HC quashed and set aside the common ITAT order and remanded the appeals for fresh adjudication. The ITAT, as the final fact-finding authority, was directed to hear the parties anew, allowing them to introduce any additional evidence, grounds, or contentions in support of their respective appeals or cross-objections.
The HC held that the absence of a DIN on the assessment order, a fundamental issue affecting its validity, was not addressed in the impugned ITAT orders. This omission goes to the root of the assessment's legality and must be considered during appeal disposal. The HC quashed and set aside the common ITAT order and remanded the appeals for fresh adjudication. The ITAT, as the final fact-finding authority, was directed to hear the parties anew, allowing them to introduce any additional evidence, grounds, or contentions in support of their respective appeals or cross-objections.
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