Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
ITAT allowed the assessee's appeal and dismissed the Revenue's grounds. The Tribunal held that accumulated funds under s.11 were expended in prior assessment years and no accumulated balance remained for application in the year under assessment; the inadvertent inclusion in Schedule I of the ITR for AY 2018-19 resulted from a "punching error." The AO's disallowance, premised on Goetze-based treatment, was rejected because the assessee neither claimed a deduction in the return nor during assessment proceedings based on prior accumulated funds. Consequently, the addition for alleged non-utilisation of accumulated funds was set aside and the Revenue's challenge was dismissed.
ITAT allowed the assessee's appeal and dismissed the Revenue's grounds. The Tribunal held that accumulated funds under s.11 were expended in prior assessment years and no accumulated balance remained for application in the year under assessment; the inadvertent inclusion in Schedule I of the ITR for AY 2018-19 resulted from a "punching error." The AO's disallowance, premised on Goetze-based treatment, was rejected because the assessee neither claimed a deduction in the return nor during assessment proceedings based on prior accumulated funds. Consequently, the addition for alleged non-utilisation of accumulated funds was set aside and the Revenue's challenge was dismissed.
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