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...
For unsecured loans under section 68, the note states that the assessee can discharge the onus by producing lender confirmation, PAN, bank statements, salary records and a reply to notice under section 133(6), thereby showing identity, creditworthiness and genuineness of the transaction. On that footing, and because the Revenue produced no contrary material, the addition was said to be unsustainable. It also notes the legal position that, for periods before 01.04.2023, section 68 did not require explanation of the source of source in unsecured-loan cases. The described effect is deletion of the addition, with consequential treatment of MAT credit, interest and penalty initiation issues.
For unsecured loans under section 68, the note states that the assessee can discharge the onus by producing lender confirmation, PAN, bank statements, salary records and a reply to notice under section 133(6), thereby showing identity, creditworthiness and genuineness of the transaction. On that footing, and because the Revenue produced no contrary material, the addition was said to be unsustainable. It also notes the legal position that, for periods before 01.04.2023, section 68 did not require explanation of the source of source in unsecured-loan cases. The described effect is deletion of the addition, with consequential treatment of MAT credit, interest and penalty initiation issues.
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