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 adjudicated a case involving reopening of assessment under section 147, addressing two primary legal issues. First, regarding notice issuance post-1-04-2021, the tribunal held that prior approval from the competent authority under section 151 was mandatory. The AO's notice was deemed invalid as procedural requirements were not strictly followed. Second, concerning share transaction allegations, the tribunal ruled against revenue, determining that reassessment proceedings constituted a change of opinion since all material was previously examined during original assessment. The tribunal found the reopening of assessment invalid, effectively deciding in favor of the assessee and against revenue's claims of bogus share transactions.
ITAT adjudicated a case involving reopening of assessment under section 147, addressing two primary legal issues. First, regarding notice issuance post-1-04-2021, the tribunal held that prior approval from the competent authority under section 151 was mandatory. The AO's notice was deemed invalid as procedural requirements were not strictly followed. Second, concerning share transaction allegations, the tribunal ruled against revenue, determining that reassessment proceedings constituted a change of opinion since all material was previously examined during original assessment. The tribunal found the reopening of assessment invalid, effectively deciding in favor of the assessee and against revenue's claims of bogus share transactions.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
