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 dominant issue was whether the mandatory prior approval under section 153D was valid, or was granted mechanically without independent application of mind. The forum held that while section 153D does not require detailed reasoning, the approving authority must record at least some indication of independent consideration; here, the approval contained no reasoning and reflected borrowed satisfaction from the AO, defeating the statutory safeguard. Consequently, assessments founded on such void approval were treated as non est in law, and the assessee's appeal was allowed. - ITAT
The dominant issue was whether the mandatory prior approval under section 153D was valid, or was granted mechanically without independent application of mind. The forum held that while section 153D does not require detailed reasoning, the approving authority must record at least some indication of independent consideration; here, the approval contained no reasoning and reflected borrowed satisfaction from the AO, defeating the statutory safeguard. Consequently, assessments founded on such void approval were treated as non est in law, and the assessee's appeal was allowed. - ITAT
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TaxTMI 
TaxTMI 
of 4916 
