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...
The Appellate Tribunal considered a case involving a revision u/s 263 regarding the validity of a Limited scrutiny Assessment. The PCIT observed that the AO did not properly examine issues u/s 36(1)(iii) and u/s 14A. It was held that the AO lacked authority to scrutinize these issues without permission. The assessment was for limited scrutiny, so the PCIT's view that the AO erred by not examining these issues was deemed incorrect. The DR agreed with this. The claim u/s 80JJAA was also discussed, with the Tribunal finding that adequate enquiries were made by the AO and the PCIT's general observation of requiring more enquiries was not valid. Regarding the issue of shares to two companies, the PCIT did not specify what further enquiries were needed, leading the Tribunal to conclude that the PCIT's revision was not justified. The appeal of the assessee was allowed.
The Appellate Tribunal considered a case involving a revision u/s 263 regarding the validity of a Limited scrutiny Assessment. The PCIT observed that the AO did not properly examine issues u/s 36(1)(iii) and u/s 14A. It was held that the AO lacked authority to scrutinize these issues without permission. The assessment was for limited scrutiny, so the PCIT's view that the AO erred by not examining these issues was deemed incorrect. The DR agreed with this. The claim u/s 80JJAA was also discussed, with the Tribunal finding that adequate enquiries were made by the AO and the PCIT's general observation of requiring more enquiries was not valid. Regarding the issue of shares to two companies, the PCIT did not specify what further enquiries were needed, leading the Tribunal to conclude that the PCIT's revision was not justified. The appeal of the assessee was allowed.
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TaxTMI 
TaxTMI 
of 4915 
