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...
Assessment made u/s 144 r.w.s. 142(1) OR 153C - The Tribunal held that the assessment made u/s 144 r.w.s. 142(1) for A.Y. 2012-13, based on the satisfaction recorded on 18.11.2013 (A.Y. 2014-15), should have been conducted u/s 153C of the Income Tax Act. The Tribunal referenced the judgments of the Hon’ble Delhi High Court and the Hon’ble Supreme Court, stating that the satisfaction note must explicitly indicate that the seized documents belong to the assessee. The Tribunal found that the assessments made were outside the scope of Section 153C, and hence, the assessment u/s 144 r.w.s. 142(1) was void ab initio.
Assessment made u/s 144 r.w.s. 142(1) OR 153C - The Tribunal held that the assessment made u/s 144 r.w.s. 142(1) for A.Y. 2012-13, based on the satisfaction recorded on 18.11.2013 (A.Y. 2014-15), should have been conducted u/s 153C of the Income Tax Act. The Tribunal referenced the judgments of the Hon’ble Delhi High Court and the Hon’ble Supreme Court, stating that the satisfaction note must explicitly indicate that the seized documents belong to the assessee. The Tribunal found that the assessments made were outside the scope of Section 153C, and hence, the assessment u/s 144 r.w.s. 142(1) was void ab initio.
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TaxTMI 
TaxTMI 
of 4915 
