Extended limitation requires willful misstatement or suppression with intent to evade; mere misclassification does not sustain confiscation or penalty...
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Computation of the block period for assessment under search-assessment provisions was determined by the date the non-searched assessee received seized documents or, where handing-over date is unavailable, by the date of issuance of the AOs satisfaction note; consequently the relevant block period placed AY 2015-16 in the 9th year. The statutory monetary threshold for issuing notices beyond the six-year block requires escaped income represented by assets of Rs.50 lakhs or more; since AOs quantified escaped income was Rs.8,84,540 (below the threshold), the extended-year notice was invalid and appellate relief for the assessee was affirmed.
Computation of the block period for assessment under search-assessment provisions was determined by the date the non-searched assessee received seized documents or, where handing-over date is unavailable, by the date of issuance of the AOs satisfaction note; consequently the relevant block period placed AY 2015-16 in the 9th year. The statutory monetary threshold for issuing notices beyond the six-year block requires escaped income represented by assets of Rs.50 lakhs or more; since AOs quantified escaped income was Rs.8,84,540 (below the threshold), the extended-year notice was invalid and appellate relief for the assessee was affirmed.
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