Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
The ITAT upheld the validity of the reassessment order under section 147 read with section 143(3), finding sufficient new material and reasons to believe that income had escaped assessment for AY 2012-13 based on investigation reports and non-compliance by the assessee. The tribunal rejected the assessee's contention of change of opinion and improper assumption of jurisdiction. However, additions made under section 68 regarding the identity, creditworthiness, and genuineness of share application money were set aside for fresh inquiry, as the AO had not fully verified the parties involved. The AO was directed to conduct further enquiries and provide the assessee with reasonable opportunity of being heard. Additionally, the matter concerning alleged accommodation entries based on the Inspector's report was remanded for reconsideration, with instructions to furnish the report to the assessee and allow them to respond. Grounds relating to these issues were allowed for statistical purposes, while others were dismissed.
The ITAT upheld the validity of the reassessment order under section 147 read with section 143(3), finding sufficient new material and reasons to believe that income had escaped assessment for AY 2012-13 based on investigation reports and non-compliance by the assessee. The tribunal rejected the assessee's contention of change of opinion and improper assumption of jurisdiction. However, additions made under section 68 regarding the identity, creditworthiness, and genuineness of share application money were set aside for fresh inquiry, as the AO had not fully verified the parties involved. The AO was directed to conduct further enquiries and provide the assessee with reasonable opportunity of being heard. Additionally, the matter concerning alleged accommodation entries based on the Inspector's report was remanded for reconsideration, with instructions to furnish the report to the assessee and allow them to respond. Grounds relating to these issues were allowed for statistical purposes, while others were dismissed.
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