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 taxpayer's appeal against revision under section 263, upholding the PCIT's order. The tribunal found that the assessing officer (Ld. AO) had not demonstrated any application of mind to the treatment of "retention money," which the taxpayer had explained was not debited to profit and loss but adjusted in the income computation. The PCIT correctly noted absence of enquiry, verification or discussion in the assessment order regarding the retention money issue. Given the lack of cogent factual or legal analysis by the AO and the recorded failure of inquiry, the ITAT held the revision to be valid and found no merit in the taxpayer's contention that the PCIT's jurisdictional exercise was improper.
ITAT dismissed the taxpayer's appeal against revision under section 263, upholding the PCIT's order. The tribunal found that the assessing officer (Ld. AO) had not demonstrated any application of mind to the treatment of "retention money," which the taxpayer had explained was not debited to profit and loss but adjusted in the income computation. The PCIT correctly noted absence of enquiry, verification or discussion in the assessment order regarding the retention money issue. Given the lack of cogent factual or legal analysis by the AO and the recorded failure of inquiry, the ITAT held the revision to be valid and found no merit in the taxpayer's contention that the PCIT's jurisdictional exercise was improper.
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TaxTMI 
TaxTMI 
of 4915 
