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...
Clubbing of income - addition of portion of sales consideration related to wife and mother of assessee u/s 64(1) - Logically the sale consideration is to be distributed between four persons. In view of that, a portion of sale consideration is required to be assigned to the rights of membership etc which were not given to the firm. Therefore, there is no transfer from husband to wife of any right or any value. In view of that no value can be assigned under Section 64(1) of the Act by applying clubbing provisions thereon. Moreover, we find that the ld CITA grossly erred in applying the clubbing provisions u/s 64(1) of the Act even for mother. - AT
Clubbing of income - addition of portion of sales consideration related to wife and mother of assessee u/s 64(1) - Logically the sale consideration is to be distributed between four persons. In view of that, a portion of sale consideration is required to be assigned to the rights of membership etc which were not given to the firm. Therefore, there is no transfer from husband to wife of any right or any value. In view of that no value can be assigned under Section 64(1) of the Act by applying clubbing provisions thereon. Moreover, we find that the ld CITA grossly erred in applying the clubbing provisions u/s 64(1) of the Act even for mother. - AT
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TaxTMI 
TaxTMI 
of 4915 
