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...
Revision under s.263 was examined on multiple deductions. Corporate club membership fees were held to be business expenditure under s.37(1), supported by binding precedent, hence the AO's allowance was not "erroneous"; revision was set aside on this issue. ESOP expense was treated as incurred in the course of business with nexus to employee compensation and consistent judicial acceptance; the AO's view was plausible, so revision failed on this issue. CSR outgo, once disallowed under s.37(1), could still qualify for s.80G if conditions were met; mere difference of opinion could not sustain s.263, so revision was quashed. Stock exchange "penalties" were compensatory charges for procedural lapses, not hit by Expln.1 to s.37(1); revision was rejected. Interest under s.36(1)(iii) lacked nexus with CWIP; proviso was inapplicable and revision was invalid; assessee's appeal allowed. - ITAT
Revision under s.263 was examined on multiple deductions. Corporate club membership fees were held to be business expenditure under s.37(1), supported by binding precedent, hence the AO's allowance was not "erroneous"; revision was set aside on this issue. ESOP expense was treated as incurred in the course of business with nexus to employee compensation and consistent judicial acceptance; the AO's view was plausible, so revision failed on this issue. CSR outgo, once disallowed under s.37(1), could still qualify for s.80G if conditions were met; mere difference of opinion could not sustain s.263, so revision was quashed. Stock exchange "penalties" were compensatory charges for procedural lapses, not hit by Expln.1 to s.37(1); revision was rejected. Interest under s.36(1)(iii) lacked nexus with CWIP; proviso was inapplicable and revision was invalid; assessee's appeal allowed. - ITAT
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