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 - it is evident that assessing officer has para-wise dealt with the objections of the appellant. We do not feel the need to delve into the issue of sufficiency of reasoning given by the assessing officer while rejecting the objections as the same is of academic nature since we have already upheld the validity of notice u/s 148. - However, AO was not justified in expanding the scope of reassessment proceedings u/s 147 without following the due course and as such the addition is in the teeth of provisions of section 147. - AT
Reopening of assessment u/s 147 - it is evident that assessing officer has para-wise dealt with the objections of the appellant. We do not feel the need to delve into the issue of sufficiency of reasoning given by the assessing officer while rejecting the objections as the same is of academic nature since we have already upheld the validity of notice u/s 148. - However, AO was not justified in expanding the scope of reassessment proceedings u/s 147 without following the due course and as such the addition is in the teeth of provisions of section 147. - AT
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TaxTMI 
TaxTMI 
of 4915 
