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 quashed reassessment proceedings initiated under Section 147 after expiry of 4-year limitation period. Court found no failure by assessee to disclose material facts fully and truly, as required by first proviso to Section 147. Information relied upon for reopening was already available in documents filed with return and during original assessment. Where matter was previously examined during assessment after raising queries, allowing reassessment would amount to impermissible review power. Reopening notice held invalid as reasons recorded failed to specify any non-disclosure of material facts by assessee.
HC quashed reassessment proceedings initiated under Section 147 after expiry of 4-year limitation period. Court found no failure by assessee to disclose material facts fully and truly, as required by first proviso to Section 147. Information relied upon for reopening was already available in documents filed with return and during original assessment. Where matter was previously examined during assessment after raising queries, allowing reassessment would amount to impermissible review power. Reopening notice held invalid as reasons recorded failed to specify any non-disclosure of material facts by assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
