Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
A composite show cause notice under Section 74 covering multiple tax periods or financial years was held impermissible. The HC relied on its earlier rulings to hold that clubbing distinct tax periods in one proceeding creates a jurisdictional defect, and a notice issued on that basis is illegal. Because the foundational show cause notice was invalid, the consequential Order-in-Original could not survive and was set aside. Liberty was reserved to initiate fresh proceedings in accordance with law, with all contentions kept open.
A composite show cause notice under Section 74 covering multiple tax periods or financial years was held impermissible. The HC relied on its earlier rulings to hold that clubbing distinct tax periods in one proceeding creates a jurisdictional defect, and a notice issued on that basis is illegal. Because the foundational show cause notice was invalid, the consequential Order-in-Original could not survive and was set aside. Liberty was reserved to initiate fresh proceedings in accordance with law, with all contentions kept open.
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