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 - The findings of CIT suffer from apparent error and incompleteness. CIT has summarily set aside the re-assessment order and shifted the responsibility on the AO to examine or verify the facts. The opportunity contemplated under Section 263 is thus rendered illusory and merely an empty formality resulting in miscarriage of justice in contravention of express intendment of provision of Section 263. - AT
Revision u/s 263 - The findings of CIT suffer from apparent error and incompleteness. CIT has summarily set aside the re-assessment order and shifted the responsibility on the AO to examine or verify the facts. The opportunity contemplated under Section 263 is thus rendered illusory and merely an empty formality resulting in miscarriage of justice in contravention of express intendment of provision of Section 263. - AT
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TaxTMI 
TaxTMI 
of 4915 
