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...
Disallowance of alleged bogus purchases/unexplained expenditure under s. 37 was held unsustainable where the AO relied solely on a third-party's subsequently retracted statement alleging invoice accommodation without delivery, without confronting or rebutting the assessee's documentary evidence. As the assessee produced recorded materials substantiating the expenditure and there was no finding of any actual purchases from the alleged biller (the group being only a transporter), and no corroborative material supporting the statement, a statement alone could not justify the addition. The disallowance was therefore deleted and the appeal of the revenue failed. - ITAT
Disallowance of alleged bogus purchases/unexplained expenditure under s. 37 was held unsustainable where the AO relied solely on a third-party's subsequently retracted statement alleging invoice accommodation without delivery, without confronting or rebutting the assessee's documentary evidence. As the assessee produced recorded materials substantiating the expenditure and there was no finding of any actual purchases from the alleged biller (the group being only a transporter), and no corroborative material supporting the statement, a statement alone could not justify the addition. The disallowance was therefore deleted and the appeal of the revenue failed. - ITAT
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