Reasonable Cause for Late Return: penalty under section 271(1)(c) unsustainable where disclosure, audit filing and voluntary offer showed no concealme...
A common satisfaction note recorded under section 153C for multiple assessment years was held to be legally unsustainable. The Tribunal, following co-ordinate bench authority, accepted that satisfaction must be recorded separately for each assessment year because a consolidated note defeats valid assumption of jurisdiction. On that basis, the assessments for the relevant years were quashed.
A common satisfaction note recorded under section 153C for multiple assessment years was held to be legally unsustainable. The Tribunal, following co-ordinate bench authority, accepted that satisfaction must be recorded separately for each assessment year because a consolidated note defeats valid assumption of jurisdiction. On that basis, the assessments for the relevant years were quashed.
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