Reasonable Cause for Late Return: penalty under section 271(1)(c) unsustainable where disclosure, audit filing and voluntary offer showed no concealme...
Where reassessment was triggered by documents found in a search on a third party, the Revenue had to proceed under the special search-assessment mechanism for "other person" cases and could not invoke general reassessment under section 147 on the same material. The Tribunal held that assumption of jurisdiction under section 147 was invalid because the very basis of action arose from third-party search material, and the reassessment was therefore vitiated. The remaining grounds were treated as academic, and the reassessment proceedings were quashed.
Where reassessment was triggered by documents found in a search on a third party, the Revenue had to proceed under the special search-assessment mechanism for "other person" cases and could not invoke general reassessment under section 147 on the same material. The Tribunal held that assumption of jurisdiction under section 147 was invalid because the very basis of action arose from third-party search material, and the reassessment was therefore vitiated. The remaining grounds were treated as academic, and the reassessment proceedings were quashed.
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