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 dismissed the appeal and upheld the provisional attachment order. The Tribunal found that the appellant failed to satisfactorily disclose the source of funds used to acquire the disputed property, including unexplained receipts aggregating Rs. 12 crore routed through intermediary entities and paid to a vendor's employee, and that documentary proof for asserted loans was not produced. The AT held that record-level statements sufficiently establish proceeds of crime and that Section 8(1) requires satisfaction on notice regarding source. The Tribunal endorsed attachment of property of equivalent value where original proceeds are unavailable and rejected mala fides/political vendetta allegations for lack of proof. The appeal therefore fails on all grounds.
AT dismissed the appeal and upheld the provisional attachment order. The Tribunal found that the appellant failed to satisfactorily disclose the source of funds used to acquire the disputed property, including unexplained receipts aggregating Rs. 12 crore routed through intermediary entities and paid to a vendor's employee, and that documentary proof for asserted loans was not produced. The AT held that record-level statements sufficiently establish proceeds of crime and that Section 8(1) requires satisfaction on notice regarding source. The Tribunal endorsed attachment of property of equivalent value where original proceeds are unavailable and rejected mala fides/political vendetta allegations for lack of proof. The appeal therefore fails on all grounds.
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TaxTMI 
TaxTMI 
of 4915 
