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 - Disallowance of STCG - FMV determination of shares - The Appellate Tribunal (AT) scrutinized the fair market value and share valuation process, concluding that the appellant failed to substantiate their claims adequately. They found discrepancies in the valuation and affirmed the PCIT's decision to reject the appellant's arguments. The AT affirmed the PCIT's characterization of the transactions as structured and not at arm's length. They concluded that the assessment order was prejudicial to the interest of the Revenue and upheld the PCIT's decision to set it aside.
Revision u/s 263 - Disallowance of STCG - FMV determination of shares - The Appellate Tribunal (AT) scrutinized the fair market value and share valuation process, concluding that the appellant failed to substantiate their claims adequately. They found discrepancies in the valuation and affirmed the PCIT's decision to reject the appellant's arguments. The AT affirmed the PCIT's characterization of the transactions as structured and not at arm's length. They concluded that the assessment order was prejudicial to the interest of the Revenue and upheld the PCIT's decision to set it aside.
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