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...
Rectification of mistake apparent on record is confined to obvious, patent errors and cannot be used to reappreciate evidence or revisit a debatable legal issue, because that would amount to an impermissible review. Applying that principle, the Tribunal noted that the revenue's objection required fresh examination of the assessee's transactions involving agreements for sale, acquisition and relinquishment of rights in immovable property, and the character of the consideration received. As no obvious error on the face of the record was shown, the rectification application was dismissed.
Rectification of mistake apparent on record is confined to obvious, patent errors and cannot be used to reappreciate evidence or revisit a debatable legal issue, because that would amount to an impermissible review. Applying that principle, the Tribunal noted that the revenue's objection required fresh examination of the assessee's transactions involving agreements for sale, acquisition and relinquishment of rights in immovable property, and the character of the consideration received. As no obvious error on the face of the record was shown, the rectification application was dismissed.
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