Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
The ITAT allowed the assessee's appeal, holding that additions made under s.153A based on seized Excel/loose third-party documents were unsupported "dumb" evidence and lacked requisite corroboration (no cash seizure, asset trace or payer confirmation), inconsistent witness accounts, and no utilization trail for the alleged huge receipts; the Tribunal set aside the CIT(A)'s finding and directed the AO to delete the Rs.23.78 crore addition. The ITAT further held the assessee retained registration under s.12A for the year in issue and, absent a sustainable finding under s.13(1)(c), is entitled to exemption under s.11. Additions predicated on materials extraneous to the relevant AY were also held unsustainable.
The ITAT allowed the assessee's appeal, holding that additions made under s.153A based on seized Excel/loose third-party documents were unsupported "dumb" evidence and lacked requisite corroboration (no cash seizure, asset trace or payer confirmation), inconsistent witness accounts, and no utilization trail for the alleged huge receipts; the Tribunal set aside the CIT(A)'s finding and directed the AO to delete the Rs.23.78 crore addition. The ITAT further held the assessee retained registration under s.12A for the year in issue and, absent a sustainable finding under s.13(1)(c), is entitled to exemption under s.11. Additions predicated on materials extraneous to the relevant AY were also held unsustainable.
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