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...
HC determined the reopening assessment under s.147 was invalid as it constituted mere change of opinion. The AO's reliance on cash deposit information from Insight Portal did not qualify as fresh material since this data was previously examined during regular assessment. The court found no legitimate basis for the AO's "reason to believe" income had escaped assessment, as the information lacked new elements establishing a live nexus. Consequently, the s.148 notice for AY 2017-18 was quashed for lack of jurisdiction. The ruling emphasizes that reassessment cannot be initiated based on reexamination of existing material already considered during original assessment proceedings.
HC determined the reopening assessment under s.147 was invalid as it constituted mere change of opinion. The AO's reliance on cash deposit information from Insight Portal did not qualify as fresh material since this data was previously examined during regular assessment. The court found no legitimate basis for the AO's "reason to believe" income had escaped assessment, as the information lacked new elements establishing a live nexus. Consequently, the s.148 notice for AY 2017-18 was quashed for lack of jurisdiction. The ruling emphasizes that reassessment cannot be initiated based on reexamination of existing material already considered during original assessment proceedings.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
