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...
Addition u/s. 68 - allegation of accommodation entries taken by assessee - initial burden to prove - once the initial burden is discharged by the assessee the burden shifts to the revenue to disprove the claim of the assessee. It is noticed that AO did not make any sort of enquiries to disprove the genuineness of the transaction on the evidences furnished by the assessee. He has completely ignored even the statement retracted by the PKJ. The addition is made merely on surmises and conjectures without probing further by the Assessing Officer. - AT
Addition u/s. 68 - allegation of accommodation entries taken by assessee - initial burden to prove - once the initial burden is discharged by the assessee the burden shifts to the revenue to disprove the claim of the assessee. It is noticed that AO did not make any sort of enquiries to disprove the genuineness of the transaction on the evidences furnished by the assessee. He has completely ignored even the statement retracted by the PKJ. The addition is made merely on surmises and conjectures without probing further by the Assessing Officer. - AT
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