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 - Applicability of provisions of 56(2)(vii)(b) - Documentary evidence available in the records which the AO admits to have verified the veracity thereof amply demonstrate that the AO made the requisite enquiry. If that be so, a mere non-discussion or non-mention thereof in the assessment order could not lead to assumption that the AO did not apply his mind or that he had not made inquiry on the issue. - Revision order set aside - AT
Revision u/s 263 - Applicability of provisions of 56(2)(vii)(b) - Documentary evidence available in the records which the AO admits to have verified the veracity thereof amply demonstrate that the AO made the requisite enquiry. If that be so, a mere non-discussion or non-mention thereof in the assessment order could not lead to assumption that the AO did not apply his mind or that he had not made inquiry on the issue. - Revision order set aside - AT
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