Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
HC held that the reassessment order dated 13.07.2022 under s.148A(d) and the consequential notice under s.148 are void for want of valid prior sanction under s.151(ii); the AO assumed jurisdiction after the three-year period expired but obtained approval from an authority specified under s.151(i) instead of the higher authority mandated by s.151(ii), thereby vitiating jurisdiction. Applying the substituted provisions and the statutory timeline (including TOLA relief), the Court quashed and set aside the impugned order and notice and allowed the assessee's appeal.
HC held that the reassessment order dated 13.07.2022 under s.148A(d) and the consequential notice under s.148 are void for want of valid prior sanction under s.151(ii); the AO assumed jurisdiction after the three-year period expired but obtained approval from an authority specified under s.151(i) instead of the higher authority mandated by s.151(ii), thereby vitiating jurisdiction. Applying the substituted provisions and the statutory timeline (including TOLA relief), the Court quashed and set aside the impugned order and notice and allowed the assessee's appeal.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4827 
Join Channel 
