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...
Addition under section 69A was sustained where the assessee's statement under section 132(4) was linked to seized material and not rebutted by credible evidence. The Tribunal found this was not a bare confession: the seized document recovered during search provided the incriminating basis, the assessee gave a detailed explanation of the cash loan, source, interest arrangement and proposed recovery, and the statement was not retracted for a long period. The later claim that the figure represented cheque recoveries was held inconsistent with the ledger account, which showed no outstanding receivable on the date of search. The addition was therefore upheld and the appeal dismissed.
Addition under section 69A was sustained where the assessee's statement under section 132(4) was linked to seized material and not rebutted by credible evidence. The Tribunal found this was not a bare confession: the seized document recovered during search provided the incriminating basis, the assessee gave a detailed explanation of the cash loan, source, interest arrangement and proposed recovery, and the statement was not retracted for a long period. The later claim that the figure represented cheque recoveries was held inconsistent with the ledger account, which showed no outstanding receivable on the date of search. The addition was therefore upheld and the appeal dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
