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 against PCIT's revision order under s.263 regarding unaccounted cash purchases of Rs.5,83,99,000/-. The Tribunal held that where AO had already estimated profits on unaccounted cash purchases, additional disallowance under s.40A(3) was not warranted. Following established HC precedents, ITAT found AO's approach of applying gross profit estimation was a plausible view, precluding PCIT's revisionary powers. The assessment considering seized materials and ledger accounts demonstrated these were trading receipts during business operations. Since profits were already estimated and taxed on cash transactions, further disallowance under s.40A(3) was legally untenable. Assessee's appeals allowed, setting aside revision proceedings.
ITAT ruled against PCIT's revision order under s.263 regarding unaccounted cash purchases of Rs.5,83,99,000/-. The Tribunal held that where AO had already estimated profits on unaccounted cash purchases, additional disallowance under s.40A(3) was not warranted. Following established HC precedents, ITAT found AO's approach of applying gross profit estimation was a plausible view, precluding PCIT's revisionary powers. The assessment considering seized materials and ledger accounts demonstrated these were trading receipts during business operations. Since profits were already estimated and taxed on cash transactions, further disallowance under s.40A(3) was legally untenable. Assessee's appeals allowed, setting aside revision proceedings.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
