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...
Revisionary review under section 263 was considered on whether the AO failed to inquire into the source of share capital and whether acceptance of a merchant banker valuation was erroneous. The tribunal found the AO had the investor's balance sheet before him, accepted the investor's creditworthiness, and that mere suspicion or association with a group did not amount to lack of inquiry. Inquiry into the source-of-source was not required, and the AO properly accepted a DCF valuation by a qualified merchant banker; revisionary interference was unwarranted and decision favoured the assessee.
Revisionary review under section 263 was considered on whether the AO failed to inquire into the source of share capital and whether acceptance of a merchant banker valuation was erroneous. The tribunal found the AO had the investor's balance sheet before him, accepted the investor's creditworthiness, and that mere suspicion or association with a group did not amount to lack of inquiry. Inquiry into the source-of-source was not required, and the AO properly accepted a DCF valuation by a qualified merchant banker; revisionary interference was unwarranted and decision favoured the assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
