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 issue is whether the assessee was an agent of an NRI partner such that income received by a partnership would be attributable to the assessee; the tribunal found the development agreement was with the partnership firm (five partners) not the individual NRI, there was no direct or indirect contractual or business connection between the assessee and the NRI partner, and income flowed to partners from the firm; therefore the tax authority failed to establish agency and the addition made invoking agent-attribution provisions was deleted in favour of the assessee.
The issue is whether the assessee was an agent of an NRI partner such that income received by a partnership would be attributable to the assessee; the tribunal found the development agreement was with the partnership firm (five partners) not the individual NRI, there was no direct or indirect contractual or business connection between the assessee and the NRI partner, and income flowed to partners from the firm; therefore the tax authority failed to establish agency and the addition made invoking agent-attribution provisions was deleted in favour of the assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
