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...
Collateral challenge to the jurisdiction of reassessment proceedings was held maintainable in an appeal against penalty where the penalty was founded on that reassessment. After three years from the end of the relevant assessment year, approval for notice under section 148 had to be obtained from the authority specified in section 151(ii); approval by the PCIT was insufficient. Because the notice under section 148 and the reassessment order were issued with the wrong sanction, the reassessment was void and the consequential penalty under section 271E could not survive.
Collateral challenge to the jurisdiction of reassessment proceedings was held maintainable in an appeal against penalty where the penalty was founded on that reassessment. After three years from the end of the relevant assessment year, approval for notice under section 148 had to be obtained from the authority specified in section 151(ii); approval by the PCIT was insufficient. Because the notice under section 148 and the reassessment order were issued with the wrong sanction, the reassessment was void and the consequential penalty under section 271E could not survive.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
