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...
Reopening of assessment u/s 147 - validity of reason to believe - ‘borrowed satisfaction’ of the DDIT (Inv.) - The repetition of certain portions of the investigation report of DDIT without any reasons independently recorded by the AO on the basis of ‘borrowed satisfaction’ of the DDIT (Inv.) cannot be the basis for reopening of assessment u/s. 147 of the Act.
Reopening of assessment u/s 147 - validity of reason to believe - ‘borrowed satisfaction’ of the DDIT (Inv.) - The repetition of certain portions of the investigation report of DDIT without any reasons independently recorded by the AO on the basis of ‘borrowed satisfaction’ of the DDIT (Inv.) cannot be the basis for reopening of assessment u/s. 147 of the Act.
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