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 allowed the assessee's appeal and quashed the revisionary order passed by PCIT u/s 263. It held that once the assessee opted for and finalized settlement under the Direct Tax Vivad Se Vishwas Act, 2020, the tax dispute stood conclusively closed and could not be reopened through revision proceedings u/s 263. Relying on binding HC precedent, ITAT concluded that the PCIT's exercise of jurisdiction was contrary to the scheme and object of the Vivad Se Vishwas Act, rendering the impugned revisional order unsustainable in law.
ITAT allowed the assessee's appeal and quashed the revisionary order passed by PCIT u/s 263. It held that once the assessee opted for and finalized settlement under the Direct Tax Vivad Se Vishwas Act, 2020, the tax dispute stood conclusively closed and could not be reopened through revision proceedings u/s 263. Relying on binding HC precedent, ITAT concluded that the PCIT's exercise of jurisdiction was contrary to the scheme and object of the Vivad Se Vishwas Act, rendering the impugned revisional order unsustainable in law.
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