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 first appellate order that merely reproduces the parties' submissions and the Assessing Officer's findings, and then reverses the assessment in a few lines by relying on another case, is inadequate because reasons are essential for appellate scrutiny and for showing application of mind to facts and law. Where the CIT(A) does not give effective adjudication, remand for fresh decision is appropriate; the Tribunal need not substitute itself as the primary appellate forum simply because it is the last fact-finding authority. Reliance on Arvind Kumar Jaiswal was found inapposite on these facts, and the remand to the CIT(A) was upheld.
A first appellate order that merely reproduces the parties' submissions and the Assessing Officer's findings, and then reverses the assessment in a few lines by relying on another case, is inadequate because reasons are essential for appellate scrutiny and for showing application of mind to facts and law. Where the CIT(A) does not give effective adjudication, remand for fresh decision is appropriate; the Tribunal need not substitute itself as the primary appellate forum simply because it is the last fact-finding authority. Reliance on Arvind Kumar Jaiswal was found inapposite on these facts, and the remand to the CIT(A) was upheld.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
