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...
Jurisdiction assumed by DCIT not challenged within stipulated period, hence cannot be questioned now. Addition u/s 68 not sustainable as summary of receipts discloses names, addresses, and telephone numbers of donors with specific directions for contributions. Matter remanded to verify authenticity of summary receipts and copies of receipts issued. Notice u/s 143(2) issued prior to intimation u/s 143(1) valid as per Supreme Court ruling in CIT vs. Gujarat Electricity Board case, where processing u/s 143(1) subsequent to notice u/s 143(2) does not invalidate the notice.
Jurisdiction assumed by DCIT not challenged within stipulated period, hence cannot be questioned now. Addition u/s 68 not sustainable as summary of receipts discloses names, addresses, and telephone numbers of donors with specific directions for contributions. Matter remanded to verify authenticity of summary receipts and copies of receipts issued. Notice u/s 143(2) issued prior to intimation u/s 143(1) valid as per Supreme Court ruling in CIT vs. Gujarat Electricity Board case, where processing u/s 143(1) subsequent to notice u/s 143(2) does not invalidate the notice.
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TaxTMI 
TaxTMI 
of 4915 
