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 held unsustainable where the...
Penalty under section 271(1)(c) deleted where income was disclosed in section 153A returns and remaining additions were only estimated or computational.
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Penalty under section 271(1)(c) was held unsustainable where the income had already been disclosed in returns filed in response to section 153A notices and accepted in assessment, because such disclosure could not by itself amount to concealment or furnishing inaccurate particulars. The Tribunal also found that the remaining additions were only estimated deemed brokerage adjustments and calculation errors, which did not meet the statutory threshold for penalty. On those facts, the penalties for the relevant assessment years were deleted.
Penalty under section 271(1)(c) was held unsustainable where the income had already been disclosed in returns filed in response to section 153A notices and accepted in assessment, because such disclosure could not by itself amount to concealment or furnishing inaccurate particulars. The Tribunal also found that the remaining additions were only estimated deemed brokerage adjustments and calculation errors, which did not meet the statutory threshold for penalty. On those facts, the penalties for the relevant assessment years were deleted.
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