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...
A consolidated satisfaction note was prepared for multiple assessment years instead of separate notes, rendering the assessment proceedings u/s 153C invalid. The ITAT held that without a separate satisfaction note establishing the seized materials' relevance to the assessee, no addition could be made without resorting to Sections 147/148 or 153C. As the twin conditions for invoking Section 263 were not met, the ITAT quashed the assessment framed u/s 153C read with Section 143(3), deciding in favor of the assessee.
A consolidated satisfaction note was prepared for multiple assessment years instead of separate notes, rendering the assessment proceedings u/s 153C invalid. The ITAT held that without a separate satisfaction note establishing the seized materials' relevance to the assessee, no addition could be made without resorting to Sections 147/148 or 153C. As the twin conditions for invoking Section 263 were not met, the ITAT quashed the assessment framed u/s 153C read with Section 143(3), deciding in favor of the assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
