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...
Revisional powers under Section 264 were held to be broad and aimed at preventing miscarriage of justice and granting relief to an assessee even where the assessee committed mistakes in the original return; consequently the revision application should have been considered and the impugned order under Section 264 was set aside. The court distinguished the Supreme Court decision in Goetze (India) Ltd., finding it inapplicable because that case did not address revisional powers under Section 264 but concerned a post filing deduction without a revised return.
Revisional powers under Section 264 were held to be broad and aimed at preventing miscarriage of justice and granting relief to an assessee even where the assessee committed mistakes in the original return; consequently the revision application should have been considered and the impugned order under Section 264 was set aside. The court distinguished the Supreme Court decision in Goetze (India) Ltd., finding it inapplicable because that case did not address revisional powers under Section 264 but concerned a post filing deduction without a revised return.
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