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...
Reopening of assessment u/s 147 - reason to believe - new regime u/s 148A - The High Court held that, the amended provisions require a prima facie satisfaction of income escapement, not merely a "reason to believe." - Further, the impugned orders passed by the AO u/s 148A(d) of the Act are bad because, Petitioners’ Objections have not been considered. Thus, apart from being in violation of principles of natural justice, the assumption of jurisdiction under Sec. 148 is perverse and unsustainable. - Notice issued u/s 148 and order u/s 148A quashed.
Reopening of assessment u/s 147 - reason to believe - new regime u/s 148A - The High Court held that, the amended provisions require a prima facie satisfaction of income escapement, not merely a "reason to believe." - Further, the impugned orders passed by the AO u/s 148A(d) of the Act are bad because, Petitioners’ Objections have not been considered. Thus, apart from being in violation of principles of natural justice, the assumption of jurisdiction under Sec. 148 is perverse and unsustainable. - Notice issued u/s 148 and order u/s 148A quashed.
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TaxTMI 
TaxTMI 
of 4916 
