As regards to the validity of the reassessment proceedings under section 147 r.w.s 148 of the Act, it is not in dispute that the A.O. is required to get the approval of the competent authority i.e; JCIT in the present case. JCIT mentioned as under: Yes, it is a fit case to issue notice under section 148 of the Income Tax Act.
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No penalty u/s.271(1)(c) can be imposed in respect of inadvertent and bona fide mistake committed by the assessee.
ITAT find that jewelry has been found during the course of search from the possession of the assessee. The jewellery was inventorised. The claim of the assessee that this has been received as a gift from relatives and friends is not at all substantiated but merely remained a claim. In view of this we do not find any infirmity in the orders of the learned lower authorities in confirming the addition of Rs. 1,867,098/– u/s 69B of the act after granting benefit of 500 g of gold jewellery to the assessee in terms of CBDT instruction number 1916.
Read the detailed analysis of ACIT Vs Tata Autocomp case by ITAT Pune. Disputed deduction of Rs.2.64 crore for Administrative Service charges, resolved in favor of the assessee.
