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...
Treatment of interest deduction under Income from Other Sources: an inadmissible claim of interest deduction that neutralises disclosed interest income and is not substantiated attracts penalty under the penalty regime for under reporting of income. Principle of consistency was held inapplicable where earlier returns were processed under summary intimation and no scrutiny assessment was carried out, because such intimation does not preclude re examination. Immunity clauses for bona fide explanations or estimation do not apply where the assessee fails to disclose all material facts, specifically the nexus between funds borrowed and loans given; on that factual failure the assessing officer's disallowance and consequent penalty were sustained.
Treatment of interest deduction under Income from Other Sources: an inadmissible claim of interest deduction that neutralises disclosed interest income and is not substantiated attracts penalty under the penalty regime for under reporting of income. Principle of consistency was held inapplicable where earlier returns were processed under summary intimation and no scrutiny assessment was carried out, because such intimation does not preclude re examination. Immunity clauses for bona fide explanations or estimation do not apply where the assessee fails to disclose all material facts, specifically the nexus between funds borrowed and loans given; on that factual failure the assessing officer's disallowance and consequent penalty were sustained.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
