Reassessment for unreturned property sales survives where transfer information, non-filing, and unsupported exemption claims establish a prima facie l...
Profit-element taxation limits additions for unaccounted flat-sale receipts and grey-market purchases, while reliable search records support partial a...
Non-participating bidders cannot disturb concluded liquidation sales on speculative prejudice, while costs for such challenges must remain proportiona...
HC ruled penalty proceedings under sections 271D and 271E require explicit satisfaction to be recorded by Assessing Officer during reassessment. Mere recording of satisfaction for section 271(1)(c) proceedings is insufficient. Following Jai Laxmi Rice Mills precedent, where penalty was quashed due to lack of specific satisfaction, the court held that DCIT's recording of satisfaction only for 271(1)(c) without addressing 271D/E requirements was legally deficient. Consequently, the notice issued under section 271E and subsequent proceedings were quashed, with judgment favoring the assessee due to procedural non-compliance in recording mandatory satisfaction.
HC ruled penalty proceedings under sections 271D and 271E require explicit satisfaction to be recorded by Assessing Officer during reassessment. Mere recording of satisfaction for section 271(1)(c) proceedings is insufficient. Following Jai Laxmi Rice Mills precedent, where penalty was quashed due to lack of specific satisfaction, the court held that DCIT's recording of satisfaction only for 271(1)(c) without addressing 271D/E requirements was legally deficient. Consequently, the notice issued under section 271E and subsequent proceedings were quashed, with judgment favoring the assessee due to procedural non-compliance in recording mandatory satisfaction.
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TaxTMI 
TaxTMI 
of 4910 
