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 on the ground of balance appearing in HSBC Bank Account, Geneva undisclosed - Nothing has been brought on record in “reasons recorded” or there is any material on record that assessee has any business connection in India and therefore amount deposited in said foreign bank account is income arisen or accrued or deemed to have arisen or deemed to have accrued in India. If at all there is some doubt about the said entity and deposits made therein, then, it is the UK Tax authorities which have to examine this issue. - No jurisdiction to the AO to reopen the case of a non-resident u/s 147 - AT
Addition on the ground of balance appearing in HSBC Bank Account, Geneva undisclosed - Nothing has been brought on record in “reasons recorded” or there is any material on record that assessee has any business connection in India and therefore amount deposited in said foreign bank account is income arisen or accrued or deemed to have arisen or deemed to have accrued in India. If at all there is some doubt about the said entity and deposits made therein, then, it is the UK Tax authorities which have to examine this issue. - No jurisdiction to the AO to reopen the case of a non-resident u/s 147 - AT
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