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...
Penalty under section 271(1)(c) was set aside for fresh adjudication where it was levied solely on the basis of the assessment order, without an independent examination in the penalty proceedings and without proper consideration of the assessee's material; the matter was restored to the Assessing Officer to provide due opportunity and follow natural justice. On penalty under section 271AAA, the Tribunal held that the provision applies only to a "specified previous year" as defined in the Explanation, and A.Y. 2011-12 did not fall within that description, so the penalty was deleted.
Penalty under section 271(1)(c) was set aside for fresh adjudication where it was levied solely on the basis of the assessment order, without an independent examination in the penalty proceedings and without proper consideration of the assessee's material; the matter was restored to the Assessing Officer to provide due opportunity and follow natural justice. On penalty under section 271AAA, the Tribunal held that the provision applies only to a "specified previous year" as defined in the Explanation, and A.Y. 2011-12 did not fall within that description, so the penalty was deleted.
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