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 determined that for proceedings under section 153C, the relevant assessment years should be AY 2017-18 to 2022-23, based on the satisfaction note recorded by AO on 10-10-2022. The assessment year in which search was conducted was AY 2023-24. Since the disputed AY 2021-22 falls within this block period, assessment should have been completed under section 153C rather than section 143(3). The assessment order dated 28.12.22 passed under section 143(3) was quashed. The Tribunal relied on established precedents regarding determination of six assessment years and proper procedure for assessment. Appeal allowed in taxpayer's favor.
ITAT determined that for proceedings under section 153C, the relevant assessment years should be AY 2017-18 to 2022-23, based on the satisfaction note recorded by AO on 10-10-2022. The assessment year in which search was conducted was AY 2023-24. Since the disputed AY 2021-22 falls within this block period, assessment should have been completed under section 153C rather than section 143(3). The assessment order dated 28.12.22 passed under section 143(3) was quashed. The Tribunal relied on established precedents regarding determination of six assessment years and proper procedure for assessment. Appeal allowed in taxpayer's favor.
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