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 quashed assessment order regarding additions under section 56(1)(vii) amounting to Rs. 139.67 crores made on basis of third-party documents found during search operations. Tribunal held that search material lacked evidentiary value without independent corroboration, following Supreme Court precedent in Common Cause case. Additional CIT's jurisdiction was challenged due to absence of valid order under section 120(4)(b). Tribunal ruled assessment order void ab-initio, citing TATA Communications Ltd case where similar jurisdictional defect invalidated proceedings. Key factors included lack of corroborative evidence linking documents to assessee, denied allegations regarding pen drive discovery, and failure to allow cross-examination of evidence. Appeal allowed in favor of assessee.
ITAT quashed assessment order regarding additions under section 56(1)(vii) amounting to Rs. 139.67 crores made on basis of third-party documents found during search operations. Tribunal held that search material lacked evidentiary value without independent corroboration, following Supreme Court precedent in Common Cause case. Additional CIT's jurisdiction was challenged due to absence of valid order under section 120(4)(b). Tribunal ruled assessment order void ab-initio, citing TATA Communications Ltd case where similar jurisdictional defect invalidated proceedings. Key factors included lack of corroborative evidence linking documents to assessee, denied allegations regarding pen drive discovery, and failure to allow cross-examination of evidence. Appeal allowed in favor of assessee.
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TaxTMI 
TaxTMI 
of 4916 
