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...
Disallowance u/s 14A - Assessee offered a suo-motto disallowance - By merely stating, that as the assessee was maintaining consolidated accounts, therefore, in the absence of separate accounts for exempt income yielding investments and its other business activities he was precluded from establishing a one-to-one nexus between the expenses and such exempt income yielding investments, in our considered view, by no means can be taken as discharge of the statutory obligation that was cast upon the A.O of recording a satisfaction that as to why the disallowance u/s 14A offered by the assessee was not to be accepted. - AT
Disallowance u/s 14A - Assessee offered a suo-motto disallowance - By merely stating, that as the assessee was maintaining consolidated accounts, therefore, in the absence of separate accounts for exempt income yielding investments and its other business activities he was precluded from establishing a one-to-one nexus between the expenses and such exempt income yielding investments, in our considered view, by no means can be taken as discharge of the statutory obligation that was cast upon the A.O of recording a satisfaction that as to why the disallowance u/s 14A offered by the assessee was not to be accepted. - AT
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