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...
Protective assessment cannot co-exist where substantive additions on the same income are sustained in the hands of the correct assessee; the tribunal found the assessing officer had identified and made substantive additions in the partners' hands which were affirmed on appeal, and therefore the protective addition against the partnership firm must be deleted because permitting both would tax the same income twice. The protective assessment is a temporary revenue-protection measure and loses relevance once the real assessee is determined and income is substantively assessed in that persons hands. The appeal was allowed and the protective addition deleted.
Protective assessment cannot co-exist where substantive additions on the same income are sustained in the hands of the correct assessee; the tribunal found the assessing officer had identified and made substantive additions in the partners' hands which were affirmed on appeal, and therefore the protective addition against the partnership firm must be deleted because permitting both would tax the same income twice. The protective assessment is a temporary revenue-protection measure and loses relevance once the real assessee is determined and income is substantively assessed in that persons hands. The appeal was allowed and the protective addition deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
