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 held that the final assessment order passed on 28.02.2023 was barred by limitation and therefore void. Per Section 144C(13), the Assessing Officer must pass the final order within one month from the end of the month in which DRP directions are received. In this case, DRP directions were received on 07.06.2022, making the deadline 31.07.2022. The TPO's effect order dated 14.07.2022 did not extend this limitation period. Additionally, the ITAT noted procedural irregularity as the draft assessment order was issued by the Faceless Assessment Centre while the final order was passed by the jurisdictional Assessing Officer, deviating from the faceless assessment system. Appeal decided in assessee's favor.
The ITAT held that the final assessment order passed on 28.02.2023 was barred by limitation and therefore void. Per Section 144C(13), the Assessing Officer must pass the final order within one month from the end of the month in which DRP directions are received. In this case, DRP directions were received on 07.06.2022, making the deadline 31.07.2022. The TPO's effect order dated 14.07.2022 did not extend this limitation period. Additionally, the ITAT noted procedural irregularity as the draft assessment order was issued by the Faceless Assessment Centre while the final order was passed by the jurisdictional Assessing Officer, deviating from the faceless assessment system. Appeal decided in assessee's favor.
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TaxTMI 
TaxTMI 
of 4916 
