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...
The ITAT held that where deemed consideration under s.50C is apparent from the return and corroborated by AIR/sale deed, the AO may make adjustments while processing under s.143(1); the assessee's contention that such adjustment is a purely debatable issue was rejected. However, because title disputes and a writ challenging the SRO-fixed FMV are pending, the SRO value cannot be treated as deemed consideration for s.50C, and the AO is obliged to refer valuation to the DVO. The ITAT set aside the CIT(A) order for lack of clear directions and restored the matter to the AO for de novo adjudication. Appeal of the assessee allowed for statistical purposes.
The ITAT held that where deemed consideration under s.50C is apparent from the return and corroborated by AIR/sale deed, the AO may make adjustments while processing under s.143(1); the assessee's contention that such adjustment is a purely debatable issue was rejected. However, because title disputes and a writ challenging the SRO-fixed FMV are pending, the SRO value cannot be treated as deemed consideration for s.50C, and the AO is obliged to refer valuation to the DVO. The ITAT set aside the CIT(A) order for lack of clear directions and restored the matter to the AO for de novo adjudication. Appeal of the assessee allowed for statistical purposes.
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