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...
The ITAT ruled that the AO's addition under section 68 and denial of exemption under section 10(38) were untenable. The Tribunal found that the AO relied merely on assumptions from an Investigation Wing report without direct evidence, while ignoring evidence furnished by the assessee. Since the purchase of shares in an earlier year was accepted by revenue, and the sale occurred through the Stock Exchange with consideration received via banking channels, the sale proceeds could not be considered unexplained cash credits under section 68. Additionally, the ITAT deleted the disallowance under section 14A, noting that the AO failed to establish that investments were made using interest-bearing funds, making administrative expenditure disallowance impermissible.
The ITAT ruled that the AO's addition under section 68 and denial of exemption under section 10(38) were untenable. The Tribunal found that the AO relied merely on assumptions from an Investigation Wing report without direct evidence, while ignoring evidence furnished by the assessee. Since the purchase of shares in an earlier year was accepted by revenue, and the sale occurred through the Stock Exchange with consideration received via banking channels, the sale proceeds could not be considered unexplained cash credits under section 68. Additionally, the ITAT deleted the disallowance under section 14A, noting that the AO failed to establish that investments were made using interest-bearing funds, making administrative expenditure disallowance impermissible.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
