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...
Section 263 revision turns on the distinction between lack of enquiry and inadequate enquiry. The Tribunal held that revision was justified where the AO had not specifically verified reversal of provision for onerous contract, but any tax on the reversal depends on whether the original provision was earlier allowed, to avoid double taxation; the matter was remitted for factual verification. For bad debts, the Tribunal held that a written-off debt satisfies section 36(1)(vii) and that revisional jurisdiction could not be used to demand further proof of irrecoverability. It also accepted evidence of buy-back tax payment and remitted Ind AS 116 lease adjustment claims for fresh examination under the Act independently of accounting standards.
Section 263 revision turns on the distinction between lack of enquiry and inadequate enquiry. The Tribunal held that revision was justified where the AO had not specifically verified reversal of provision for onerous contract, but any tax on the reversal depends on whether the original provision was earlier allowed, to avoid double taxation; the matter was remitted for factual verification. For bad debts, the Tribunal held that a written-off debt satisfies section 36(1)(vii) and that revisional jurisdiction could not be used to demand further proof of irrecoverability. It also accepted evidence of buy-back tax payment and remitted Ind AS 116 lease adjustment claims for fresh examination under the Act independently of accounting standards.
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TaxTMI 
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