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Search-assessment proviso jurisdiction, time-barred valuation reports, and denial of cross-examination vitiate valuation-based and confession-based ad...
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ITAT refused to condone a 1023-day delay in filing the quantum appeal, holding that a conscious decision not to pursue the statutory remedy after weighing tax effect and litigation cost was not sufficient cause. The quantum appeal was therefore dismissed as time-barred without examining the merits. On penalty, the Tribunal held that disallowance of a CSR-related donation claim under section 80G did not by itself establish misreporting under section 270A. As no suppression of facts, false entries, or fabricated evidence was found, and the assessee had disclosed all primary facts, the explanation was bona fide and protected by section 270A(6)(a). The penalty was deleted.
ITAT refused to condone a 1023-day delay in filing the quantum appeal, holding that a conscious decision not to pursue the statutory remedy after weighing tax effect and litigation cost was not sufficient cause. The quantum appeal was therefore dismissed as time-barred without examining the merits. On penalty, the Tribunal held that disallowance of a CSR-related donation claim under section 80G did not by itself establish misreporting under section 270A. As no suppression of facts, false entries, or fabricated evidence was found, and the assessee had disclosed all primary facts, the explanation was bona fide and protected by section 270A(6)(a). The penalty was deleted.
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