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...
A reassessment notice issued under section 148 beyond three years from the end of the relevant assessment year required prior approval from the PCCIT under section 151(ii). Approval from the PCIT was insufficient because the controlling date for identifying the competent sanctioning authority is the date of issue of the section 148 notice. Sanction obtained at the section 148A stage could not replace the separate approval required for issuance of the reopening notice. The Tribunal therefore treated the notice as invalid and quashed the consequential reassessment.
A reassessment notice issued under section 148 beyond three years from the end of the relevant assessment year required prior approval from the PCCIT under section 151(ii). Approval from the PCIT was insufficient because the controlling date for identifying the competent sanctioning authority is the date of issue of the section 148 notice. Sanction obtained at the section 148A stage could not replace the separate approval required for issuance of the reopening notice. The Tribunal therefore treated the notice as invalid and quashed the consequential reassessment.
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TaxTMI 
TaxTMI 
of 4915 
