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 upheld the validity of reopening under s.148 (reasons recorded, sanction obtained, survey-linked information), dismissing the challenge to jurisdiction and the plea for s.153C. However, the Tribunal allowed the appeal on substantive additions: it held that CIT(A) wrongly exercised powers under s.251(2) read with s.145(3) without applying accepted accounting/project completion methods, rendering those additions bad in law; consequential disallowances and construction-expense additions sustained by AO/CIT(A) were deleted. The cancellation of registration under s.12AA and related presumptive additions were not sustained, and the impugned additions are set aside in favour of the assessee.
ITAT upheld the validity of reopening under s.148 (reasons recorded, sanction obtained, survey-linked information), dismissing the challenge to jurisdiction and the plea for s.153C. However, the Tribunal allowed the appeal on substantive additions: it held that CIT(A) wrongly exercised powers under s.251(2) read with s.145(3) without applying accepted accounting/project completion methods, rendering those additions bad in law; consequential disallowances and construction-expense additions sustained by AO/CIT(A) were deleted. The cancellation of registration under s.12AA and related presumptive additions were not sustained, and the impugned additions are set aside in favour of the assessee.
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TaxTMI 
TaxTMI 
of 4915 
