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 dismissed the appeal, upholding the penalty under Section 271D for accepting cash loans/deposits in violation of Section 269SS. The tribunal found no substantive evidence supporting the appellant's claim of bona fide belief or reasonable cause for cash transactions. The appellant failed to establish factual foundations demonstrating why the statutory provisions were inapplicable. The tribunal emphasized that mere assertions without concrete proof cannot negate the penalty. Consequently, the lower authorities' orders were confirmed, and the appeal was dismissed, maintaining the imposed penalty for non-compliance with statutory cash transaction restrictions.
ITAT dismissed the appeal, upholding the penalty under Section 271D for accepting cash loans/deposits in violation of Section 269SS. The tribunal found no substantive evidence supporting the appellant's claim of bona fide belief or reasonable cause for cash transactions. The appellant failed to establish factual foundations demonstrating why the statutory provisions were inapplicable. The tribunal emphasized that mere assertions without concrete proof cannot negate the penalty. Consequently, the lower authorities' orders were confirmed, and the appeal was dismissed, maintaining the imposed penalty for non-compliance with statutory cash transaction restrictions.
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