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...
HC upheld the ITAT's decision classifying the Trust as an Association of Persons (AOP), thereby disallowing interest paid to beneficiaries u/s 40(b). The AO found beneficiaries voluntarily pooled funds with clear intent to undertake project work and generate profits. The trust's self-declaration as an AOP and failure to rectify this status substantiated the classification. The court determined the findings were not perverse and the lower authorities' orders were legally justified, maintaining the disallowance of interest payments to beneficiaries.
HC upheld the ITAT's decision classifying the Trust as an Association of Persons (AOP), thereby disallowing interest paid to beneficiaries u/s 40(b). The AO found beneficiaries voluntarily pooled funds with clear intent to undertake project work and generate profits. The trust's self-declaration as an AOP and failure to rectify this status substantiated the classification. The court determined the findings were not perverse and the lower authorities' orders were legally justified, maintaining the disallowance of interest payments to beneficiaries.
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TaxTMI 
TaxTMI 
of 4916 
