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 the 10% tolerance band in the proviso to s.43CA applies retrospectively to the year under consideration, such that where the difference between the DVO valuation and sale consideration is within 10% no deeming addition arises. Applying the proviso and the Tribunal's precedent, the panel found the variance fell within the tolerance band for AY 2017-18 and therefore deleted the addition under s.43CA. The Tribunal affirmed the CIT(A)'s deletion of the addition, concluding there was no infirmity in treating the sale consideration as the full value of consideration for the impugned assessment year. Decided in favour of assessee.
The ITAT held that the 10% tolerance band in the proviso to s.43CA applies retrospectively to the year under consideration, such that where the difference between the DVO valuation and sale consideration is within 10% no deeming addition arises. Applying the proviso and the Tribunal's precedent, the panel found the variance fell within the tolerance band for AY 2017-18 and therefore deleted the addition under s.43CA. The Tribunal affirmed the CIT(A)'s deletion of the addition, concluding there was no infirmity in treating the sale consideration as the full value of consideration for the impugned assessment year. Decided in favour of assessee.
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TaxTMI 
TaxTMI 
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