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 penalty proceedings under Sections 271D, 271DA, and 271E cannot proceed without the Assessing Officer's recorded satisfaction regarding contraventions of Sections 269SS, 269ST, or 269T. The absence of explicit satisfaction notes in assessment orders renders consequential penalty proceedings invalid. The court granted respondents an opportunity to produce relevant records or file an affidavit-in-opposition disclosing additional material within two weeks, thereby preserving the potential for future penalty proceedings subject to proper documentation of statutory contraventions.
HC held that penalty proceedings under Sections 271D, 271DA, and 271E cannot proceed without the Assessing Officer's recorded satisfaction regarding contraventions of Sections 269SS, 269ST, or 269T. The absence of explicit satisfaction notes in assessment orders renders consequential penalty proceedings invalid. The court granted respondents an opportunity to produce relevant records or file an affidavit-in-opposition disclosing additional material within two weeks, thereby preserving the potential for future penalty proceedings subject to proper documentation of statutory contraventions.
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TaxTMI 
TaxTMI 
of 4915 
