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...
Penalty u/s. 271D - Failure to record any satisfaction for initiating the said penalty proceedings by the A.O - Tribunal held that, the issue before us is no more resintegra in light of the judgment of the Hon’ble Supreme Court in the case of CIT Vs. Jai Laxmi Rice Mills Ambala City [2023 (10) TMI 707 - GUJARAT HIGH COURT], therefore, in the backdrop of our aforesaid deliberations, the penalty imposed by the Jt.CIT u/s. 271D of the Act cannot be sustained and is liable to be struck down for want of valid assumption of jurisdiction.
Penalty u/s. 271D - Failure to record any satisfaction for initiating the said penalty proceedings by the A.O - Tribunal held that, the issue before us is no more resintegra in light of the judgment of the Hon’ble Supreme Court in the case of CIT Vs. Jai Laxmi Rice Mills Ambala City [2023 (10) TMI 707 - GUJARAT HIGH COURT], therefore, in the backdrop of our aforesaid deliberations, the penalty imposed by the Jt.CIT u/s. 271D of the Act cannot be sustained and is liable to be struck down for want of valid assumption of jurisdiction.
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TaxTMI 
TaxTMI 
of 4915 
