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...
AT affirmed the Adjudicating Authority's finding that the transaction was benami, holding that funds advanced by the beneficial owner to effect purchase were consideration, not a genuine loan to the benamidar, and thus upheld the Provisional Attachment Order. The tribunal found admissions that the alleged loan of Rs. 15,10,000 remained unpaid, inconsistent financial statements and ITRs undermining the appellant's capital-account defense, and that statutory restrictions necessitated entry in the benamidar's name. Having concluded the property was acquired for the future benefit of the beneficial owner and not pursuant to a bona fide loan or tripartite arrangement, AT dismissed the appeals and refused to interfere with the impugned order.
AT affirmed the Adjudicating Authority's finding that the transaction was benami, holding that funds advanced by the beneficial owner to effect purchase were consideration, not a genuine loan to the benamidar, and thus upheld the Provisional Attachment Order. The tribunal found admissions that the alleged loan of Rs. 15,10,000 remained unpaid, inconsistent financial statements and ITRs undermining the appellant's capital-account defense, and that statutory restrictions necessitated entry in the benamidar's name. Having concluded the property was acquired for the future benefit of the beneficial owner and not pursuant to a bona fide loan or tripartite arrangement, AT dismissed the appeals and refused to interfere with the impugned order.
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TaxTMI 
TaxTMI 
of 4916 
