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 - concept of change of opinion - The court agreed with the petitioner's argument, stating that the reopening of the assessment was indeed based on a change of opinion by the Assessing Officer, as the issue had already been considered and no additions were made during the original assessment proceedings. The court held that such a change of opinion did not justify the assumption that income chargeable to tax had escaped assessment.
Reopening of assessment - concept of change of opinion - The court agreed with the petitioner's argument, stating that the reopening of the assessment was indeed based on a change of opinion by the Assessing Officer, as the issue had already been considered and no additions were made during the original assessment proceedings. The court held that such a change of opinion did not justify the assumption that income chargeable to tax had escaped assessment.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
