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 the Assessment Order u/s 147 was void ab initio as the Assessing Officer (AO) lacked tangible material to form a valid belief of income escapement. The AO failed to provide specific details or undertake additional enquiries beyond the original assessment proceedings. The ITAT affirmed that the assessee had fully disclosed material facts, including share applicants' details, PAN, and ITRs, demonstrating creditworthiness. Consequently, the reassessment notice was quashed, and the order was decided in favor of the assessee, emphasizing the need for concrete evidence to initiate reassessment proceedings.
HC held that the Assessment Order u/s 147 was void ab initio as the Assessing Officer (AO) lacked tangible material to form a valid belief of income escapement. The AO failed to provide specific details or undertake additional enquiries beyond the original assessment proceedings. The ITAT affirmed that the assessee had fully disclosed material facts, including share applicants' details, PAN, and ITRs, demonstrating creditworthiness. Consequently, the reassessment notice was quashed, and the order was decided in favor of the assessee, emphasizing the need for concrete evidence to initiate reassessment proceedings.
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