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 (ITAT) considered the validity of proceedings u/s 153C, focusing on whether the satisfaction note recorded by the AO of the searched person was present. The AO stated that the additions to the assessee's income were not based on incriminating material and did not hold up. Additionally, the AO planned to initiate proceedings u/s 148 following the prescribed procedure u/s 148A. As the Revenue acknowledged the lack of incriminating material and initiated proceedings u/s 148, the appeals challenging the additions u/s 153C were upheld, resulting in the assessee's appeal being allowed.
The Appellate Tribunal (ITAT) considered the validity of proceedings u/s 153C, focusing on whether the satisfaction note recorded by the AO of the searched person was present. The AO stated that the additions to the assessee's income were not based on incriminating material and did not hold up. Additionally, the AO planned to initiate proceedings u/s 148 following the prescribed procedure u/s 148A. As the Revenue acknowledged the lack of incriminating material and initiated proceedings u/s 148, the appeals challenging the additions u/s 153C were upheld, resulting in the assessee's appeal being allowed.
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