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 held that Form 26AS with apparent errors cannot constitute tangible material for reopening assessment. The assessment order was invalid as duplicate entries in Form 26AS showed only a minimal discrepancy of Rs. 1,926/- in salary income. The revenue's argument regarding extended limitation period was rejected. The AO lacked sufficient grounds to believe income had escaped assessment. Appellate authorities CIT(A) and ITAT concurred that the reassessment was unsustainable. The court ultimately decided in favor of the assessee, nullifying the reassessment proceedings due to lack of substantive evidence of income escapement.
HC held that Form 26AS with apparent errors cannot constitute tangible material for reopening assessment. The assessment order was invalid as duplicate entries in Form 26AS showed only a minimal discrepancy of Rs. 1,926/- in salary income. The revenue's argument regarding extended limitation period was rejected. The AO lacked sufficient grounds to believe income had escaped assessment. Appellate authorities CIT(A) and ITAT concurred that the reassessment was unsustainable. The court ultimately decided in favor of the assessee, nullifying the reassessment proceedings due to lack of substantive evidence of income escapement.
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