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 40A(2) - disallowance of interest claim of 9% - ITAT has rightly concluded that the provisions like Section 40A are meant to check evasion of tax through excessive or unreasonable payment to relatives and associate concerns and should not be applied in a manner which will cause hardship in bonafide cases relying on Section 40A(2) - it is not a case of tax evasion in as much as it is not the Revenue’s case if the rate would have been less the assessee’s profit would have been more. - HC
Addition u/s 40A(2) - disallowance of interest claim of 9% - ITAT has rightly concluded that the provisions like Section 40A are meant to check evasion of tax through excessive or unreasonable payment to relatives and associate concerns and should not be applied in a manner which will cause hardship in bonafide cases relying on Section 40A(2) - it is not a case of tax evasion in as much as it is not the Revenue’s case if the rate would have been less the assessee’s profit would have been more. - HC
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