Reasonable Cause for Late Return: penalty under section 271(1)(c) unsustainable where disclosure, audit filing and voluntary offer showed no concealme...
Reopening under reassessment provisions was upheld where the Assessing Officer relied on tangible seized material, printouts and a statement recorded during GST proceedings plus information from a third party, providing a prima facie basis to form belief that income escaped assessment; retraction of the statement did not, absent evidence of coercion, negate the seized material and did not vitiate the reopening. The revenue's adoption of the valuation determined by CGST/Central Excise was accepted in the assessee's hands, and a conservative job work charge at the lower end of the 4%-12% market range (adjusted for diamonds) was sustained.
Reopening under reassessment provisions was upheld where the Assessing Officer relied on tangible seized material, printouts and a statement recorded during GST proceedings plus information from a third party, providing a prima facie basis to form belief that income escaped assessment; retraction of the statement did not, absent evidence of coercion, negate the seized material and did not vitiate the reopening. The revenue's adoption of the valuation determined by CGST/Central Excise was accepted in the assessee's hands, and a conservative job work charge at the lower end of the 4%-12% market range (adjusted for diamonds) was sustained.
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