Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
The ITAT upheld the CIT(A)'s deletion of the addition based on estimating net profit at 2.24% of turnover, holding that such addition constituted double taxation since the surrendered income already accounted for discrepancies in books without rejection of accounts. Consequently, the ground challenging this addition was dismissed. Further, the Tribunal ruled that surrendered income disclosed under "Income from Other Sources" could not be taxed under section 115BBE as it was not assessed as deemed income under sections 68, 69, 69A, 69B, 69C, or 69D. The AO was accordingly directed not to apply section 115BBE, and the CIT(A)'s order in this regard was affirmed.
The ITAT upheld the CIT(A)'s deletion of the addition based on estimating net profit at 2.24% of turnover, holding that such addition constituted double taxation since the surrendered income already accounted for discrepancies in books without rejection of accounts. Consequently, the ground challenging this addition was dismissed. Further, the Tribunal ruled that surrendered income disclosed under "Income from Other Sources" could not be taxed under section 115BBE as it was not assessed as deemed income under sections 68, 69, 69A, 69B, 69C, or 69D. The AO was accordingly directed not to apply section 115BBE, and the CIT(A)'s order in this regard was affirmed.
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