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...
Assessment u/s 153A - admission made u/s 132(4) - The fundamental difference between evidentiary value of statement under S. 132(4) against the maker of statement vis-a-vis a third party has not been recognised by the revenue. The statement of the maker may possibly operate as estoppel against him in certain circumstances. However, truthfulness thereof is required to be proved beyond doubt for it to bind a third party. The deptt. was duty bound to give cross examination of the maker where it seeks to rely upon it. - AT
Assessment u/s 153A - admission made u/s 132(4) - The fundamental difference between evidentiary value of statement under S. 132(4) against the maker of statement vis-a-vis a third party has not been recognised by the revenue. The statement of the maker may possibly operate as estoppel against him in certain circumstances. However, truthfulness thereof is required to be proved beyond doubt for it to bind a third party. The deptt. was duty bound to give cross examination of the maker where it seeks to rely upon it. - AT
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TaxTMI 
TaxTMI 
of 4915 
