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...
Disallowing interest u/s. 36(1)(iii) - CIT(A) allowed the claim - AO is drawing adverse inference that assessee has not submitted the utilization of the overdraft in the earlier years. We note that this is not the case, where AO has any power to reopen the case of earlier years or that the AO has stepped into the shoes of ld. CIT and is exercising jurisdiction u/s 263 and that also for earlier year. No cogent rebuttal has been given on behalf of the revenue against the finding given by ld. - AT
Disallowing interest u/s. 36(1)(iii) - CIT(A) allowed the claim - AO is drawing adverse inference that assessee has not submitted the utilization of the overdraft in the earlier years. We note that this is not the case, where AO has any power to reopen the case of earlier years or that the AO has stepped into the shoes of ld. CIT and is exercising jurisdiction u/s 263 and that also for earlier year. No cogent rebuttal has been given on behalf of the revenue against the finding given by ld. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
