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...
AT determined that a gold purchase transaction of Rs. 1 Crore constituted a benami transaction under PBPTA. The transaction involved RTGS transfer from A's account to firm H, but gold delivery was made to M instead of A. Despite having A's signed invoice received through M, the appellant failed to establish direct delivery to A. Several suspicious elements emerged: cash deposit by non-account holder A, involvement of M who was partner in appellant's other firm B, subsequent closure of H's bank account with proceeds transferred to B where M was also partner. The appellant's claim of good faith was rejected due to irregular business practices and unexplained circumstances surrounding the transaction. The pattern of fund transfer, delivery arrangements, and business relationships indicated deliberate circumvention of normal procedures. Appeal dismissed.
AT determined that a gold purchase transaction of Rs. 1 Crore constituted a benami transaction under PBPTA. The transaction involved RTGS transfer from A's account to firm H, but gold delivery was made to M instead of A. Despite having A's signed invoice received through M, the appellant failed to establish direct delivery to A. Several suspicious elements emerged: cash deposit by non-account holder A, involvement of M who was partner in appellant's other firm B, subsequent closure of H's bank account with proceeds transferred to B where M was also partner. The appellant's claim of good faith was rejected due to irregular business practices and unexplained circumstances surrounding the transaction. The pattern of fund transfer, delivery arrangements, and business relationships indicated deliberate circumvention of normal procedures. Appeal dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
