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 HC held that the respondent Assessing Officer lacked jurisdiction to reopen assessment, finding the impugned show-cause notices constituted a mere fishing inquiry and were issued without material having a live nexus to the sale-deed. Information from the public domain and the DVO's valuation report were held insufficient to prima facie establish payment of on-money; the valuation report being only an opinion requiring corroborative evidence. Because the records showed the sale-deed predated the search and transactions relied upon, the notices were held to be without jurisdiction and were quashed and set aside, with consequential relief as appropriate to the petitioners.
The HC held that the respondent Assessing Officer lacked jurisdiction to reopen assessment, finding the impugned show-cause notices constituted a mere fishing inquiry and were issued without material having a live nexus to the sale-deed. Information from the public domain and the DVO's valuation report were held insufficient to prima facie establish payment of on-money; the valuation report being only an opinion requiring corroborative evidence. Because the records showed the sale-deed predated the search and transactions relied upon, the notices were held to be without jurisdiction and were quashed and set aside, with consequential relief as appropriate to the petitioners.
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TaxTMI 
TaxTMI 
of 4915 
