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...
Reopening of assessment was held invalid where the PCIT's approval consisted only of the terse statement "yes, I am satisfied" without recorded reasons; such mechanical approval fails the requirement that the approving officer must record satisfaction and reasons, rendering the issuance of notice and consequential assessment legally unsustainable. The tribunal relied on precedent holding similar formulaic endorsements inadequate, and accordingly quashed the notice for reopening and the assessment framed following that approval for want of valid administrative satisfaction.
Reopening of assessment was held invalid where the PCIT's approval consisted only of the terse statement "yes, I am satisfied" without recorded reasons; such mechanical approval fails the requirement that the approving officer must record satisfaction and reasons, rendering the issuance of notice and consequential assessment legally unsustainable. The tribunal relied on precedent holding similar formulaic endorsements inadequate, and accordingly quashed the notice for reopening and the assessment framed following that approval for want of valid administrative satisfaction.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
