Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
The ITAT held that the AO's order was not erroneous or prejudicial to the revenue despite no addition being made for accommodation entries following reopening under section 147. The AO had duly examined and verified the issues during reassessment and found no grounds for addition. The PCIT's revision under section 263, asserting the AO's order was erroneous, was therefore unjustified. The Tribunal set aside the PCIT's order and allowed the assessee's appeal, affirming that absence of addition does not automatically render the AO's order erroneous if the matter was properly considered during reassessment.
The ITAT held that the AO's order was not erroneous or prejudicial to the revenue despite no addition being made for accommodation entries following reopening under section 147. The AO had duly examined and verified the issues during reassessment and found no grounds for addition. The PCIT's revision under section 263, asserting the AO's order was erroneous, was therefore unjustified. The Tribunal set aside the PCIT's order and allowed the assessee's appeal, affirming that absence of addition does not automatically render the AO's order erroneous if the matter was properly considered during reassessment.
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