Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
The ITAT allowed the assessee's appeals, set aside the CIT(A)'s orders and directed the AO to delete contested additions. The Tribunal held the impugned addition resulting in double taxation unsustainable because the assessee had suo motu disclosed and offered the amounts under appropriate heads. The adhoc 50% disallowance of motor car lease and maintenance was quashed for lack of findings and reliance on conjecture rather than evidentiary record (logbook/use), and the notional interest addition on interest-free advances was deleted given the assessee's demonstrable availability of interest-free funds and absence of basis for imputing interest. All grounds were allowed and remitted for deletion.
The ITAT allowed the assessee's appeals, set aside the CIT(A)'s orders and directed the AO to delete contested additions. The Tribunal held the impugned addition resulting in double taxation unsustainable because the assessee had suo motu disclosed and offered the amounts under appropriate heads. The adhoc 50% disallowance of motor car lease and maintenance was quashed for lack of findings and reliance on conjecture rather than evidentiary record (logbook/use), and the notional interest addition on interest-free advances was deleted given the assessee's demonstrable availability of interest-free funds and absence of basis for imputing interest. All grounds were allowed and remitted for deletion.
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