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...
Revision u/s 263 - Out of the three issues raised in the show cause notice u/s 263 of the Act, in two issues ld. AO has conducted complete enquiry during re-assessment proceedings and on the third issue, the very basic facts adopted by ld. Pr. CIT for involving provision of Section 263 of the Act suffers from defect and, therefore, the proceedings u/s 263 of the Act are bad in law. Further, in view of the settled legal position, legally also, no addition can be made on any new issue without issuing a fresh show cause notice u/s 148 of the Act if no addition has been made by the AO in the re-assessment proceedings on the issue raised in the reasons recorded - AT
Revision u/s 263 - Out of the three issues raised in the show cause notice u/s 263 of the Act, in two issues ld. AO has conducted complete enquiry during re-assessment proceedings and on the third issue, the very basic facts adopted by ld. Pr. CIT for involving provision of Section 263 of the Act suffers from defect and, therefore, the proceedings u/s 263 of the Act are bad in law. Further, in view of the settled legal position, legally also, no addition can be made on any new issue without issuing a fresh show cause notice u/s 148 of the Act if no addition has been made by the AO in the re-assessment proceedings on the issue raised in the reasons recorded - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
