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...
ITAT upheld rejection of the books under section 145(3) and best judgment assessment under section 144 because the assessee did not furnish complete details or supporting evidence. After rejection of the books, income had to be estimated on a reasonable basis; the Tribunal found the AO's 10% net profit rate unsupported by comparable cases or the assessee's past results and reduced it to 6% of gross turnover, with credit for income already declared. It further held that separate section 68 additions for sundry creditors and unsecured loans could not survive once business income was estimated, absent independent incriminating material, and deleted those additions in full.
ITAT upheld rejection of the books under section 145(3) and best judgment assessment under section 144 because the assessee did not furnish complete details or supporting evidence. After rejection of the books, income had to be estimated on a reasonable basis; the Tribunal found the AO's 10% net profit rate unsupported by comparable cases or the assessee's past results and reduced it to 6% of gross turnover, with credit for income already declared. It further held that separate section 68 additions for sundry creditors and unsecured loans could not survive once business income was estimated, absent independent incriminating material, and deleted those additions in full.
Note: It is a system-generated summary and is for quick reference only.