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...
Reassessment notice under section 148 was sustained because the Assessing Officer had independent information forming reasons to believe that income had escaped assessment by a wrong claim of deduction; accordingly reassessment proceedings were validly initiated. On the substantive claim under section 80IB(10), the notional entry arising from a joint venture accounting valuation did not represent real income in the relevant year as no approved housing project activity, sales or completion occurred; applying the real income principle and to avoid double taxation, the disallowance of the deduction was deleted and the related additions were reversed.
Reassessment notice under section 148 was sustained because the Assessing Officer had independent information forming reasons to believe that income had escaped assessment by a wrong claim of deduction; accordingly reassessment proceedings were validly initiated. On the substantive claim under section 80IB(10), the notional entry arising from a joint venture accounting valuation did not represent real income in the relevant year as no approved housing project activity, sales or completion occurred; applying the real income principle and to avoid double taxation, the disallowance of the deduction was deleted and the related additions were reversed.
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