Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
ITAT allowed the appeal, set aside the impugned order of the Commissioner and held the assessee's application for regular registration u/s 80G(5) to be within limitation. The Tribunal found the proviso's first clause-requiring filing six months prior to expiry of provisional approval-applicable because provisional registration extended to A.Y. 2025-26 and the application was filed on 30.09.2024; the second clause (six months from commencement of activities) was inapplicable to an entity which commenced activities in 1952. The matter is remitted to the Commissioner to treat the application as valid and decide merits afresh. Appeal allowed for statistical purposes.
ITAT allowed the appeal, set aside the impugned order of the Commissioner and held the assessee's application for regular registration u/s 80G(5) to be within limitation. The Tribunal found the proviso's first clause-requiring filing six months prior to expiry of provisional approval-applicable because provisional registration extended to A.Y. 2025-26 and the application was filed on 30.09.2024; the second clause (six months from commencement of activities) was inapplicable to an entity which commenced activities in 1952. The matter is remitted to the Commissioner to treat the application as valid and decide merits afresh. Appeal allowed for statistical purposes.
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