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 note contrasts the scope of reopening under Section 147 with proceedings under Section 148A, stating that 148A requires only prima facie satisfaction to initiate reassessment while Section 147 involves final determination on escapement of income. It records the principle that cross examination of a person whose statement under search proceedings is relied upon is not mandatory at the 148A stage but becomes necessary when issuing a Section 147 order if that statement is the basis for reassessment. An Assessing Officer inviting a witness for cross examination at the 148A stage does not convert that invitation into a statutory obligation; the petitioner may be afforded cross examination in subsequent proceedings.
The note contrasts the scope of reopening under Section 147 with proceedings under Section 148A, stating that 148A requires only prima facie satisfaction to initiate reassessment while Section 147 involves final determination on escapement of income. It records the principle that cross examination of a person whose statement under search proceedings is relied upon is not mandatory at the 148A stage but becomes necessary when issuing a Section 147 order if that statement is the basis for reassessment. An Assessing Officer inviting a witness for cross examination at the 148A stage does not convert that invitation into a statutory obligation; the petitioner may be afforded cross examination in subsequent proceedings.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
