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 - claim of deduction u/s 36(1)(viia) - provision for Non-Performing Advances as per the RBI Regulations - The court observed that the petitioner had adequately addressed the AO's queries regarding the deduction claim during the original assessment. Additionally, the court noted that the petitioner had not claimed any deduction for rural advances, contradicting the basis for the alleged escapement of income. - The court deemed the reopening of the assessment as a clear case of change of opinion by the AO, which did not justify reassessment.
Reopening of assessment u/s 147 - claim of deduction u/s 36(1)(viia) - provision for Non-Performing Advances as per the RBI Regulations - The court observed that the petitioner had adequately addressed the AO's queries regarding the deduction claim during the original assessment. Additionally, the court noted that the petitioner had not claimed any deduction for rural advances, contradicting the basis for the alleged escapement of income. - The court deemed the reopening of the assessment as a clear case of change of opinion by the AO, which did not justify reassessment.
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TaxTMI 
TaxTMI 
of 4915 
