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...
ITAT ruled that Assessing Officer (AO) did not exceed jurisdiction in conducting complete scrutiny without additional approval. Case involved three significant factors: non-submission of mandatory assets/liabilities schedule for high-income taxpayer, substantial lending operations disproportionate to reported income, and significant loan settlements requiring verification. These aspects inherently warranted comprehensive examination beyond limited scrutiny parameters. CIT(A)'s observation regarding procedural non-compliance with CBDT circular for conversion from limited to unlimited scrutiny was deemed erroneous, as initial selection parameters themselves justified complete scrutiny. Given the nature of financial transactions and reporting requirements, case was inherently qualified for comprehensive examination from inception. ITAT held AO's actions were within jurisdictional scope.
ITAT ruled that Assessing Officer (AO) did not exceed jurisdiction in conducting complete scrutiny without additional approval. Case involved three significant factors: non-submission of mandatory assets/liabilities schedule for high-income taxpayer, substantial lending operations disproportionate to reported income, and significant loan settlements requiring verification. These aspects inherently warranted comprehensive examination beyond limited scrutiny parameters. CIT(A)'s observation regarding procedural non-compliance with CBDT circular for conversion from limited to unlimited scrutiny was deemed erroneous, as initial selection parameters themselves justified complete scrutiny. Given the nature of financial transactions and reporting requirements, case was inherently qualified for comprehensive examination from inception. ITAT held AO's actions were within jurisdictional scope.
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TaxTMI 
TaxTMI 
of 4915 
