Reasonable Cause for Late Return: penalty under section 271(1)(c) unsustainable where disclosure, audit filing and voluntary offer showed no concealme...
Reopening of assessment initiated on basis of a third party search was invalid because the assessing officer issued a notice under the general reassessment provision instead of the provision applicable to material seized in a third party search; accordingly the reassessment notice was quashed and the assessee's ground on that point allowed. The appellate authority's deletion of the addition under unexplained cash loan/interest was noted. Objection that the assessment order was cryptic or passed hastily was rejected: delay by the assessee in filing return and seeking reasons, and limitation pressures, meant the gap before final order did not invalidate the assessment process.
Reopening of assessment initiated on basis of a third party search was invalid because the assessing officer issued a notice under the general reassessment provision instead of the provision applicable to material seized in a third party search; accordingly the reassessment notice was quashed and the assessee's ground on that point allowed. The appellate authority's deletion of the addition under unexplained cash loan/interest was noted. Objection that the assessment order was cryptic or passed hastily was rejected: delay by the assessee in filing return and seeking reasons, and limitation pressures, meant the gap before final order did not invalidate the assessment process.
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