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 271AAD authorises only the Assessing Officer, Joint Commissioner (Appeals) and Commissioner (Appeals) to initiate or impose penalty for false entries in books of account; it does not confer that power on the Principal Commissioner or Commissioner. Penalty is not automatic and requires a final determination that a false entry exists. Revisionary jurisdiction cannot be used to direct the Assessing Officer to commence section 271AAD penalty proceedings while the underlying disallowance of contract expenditure remains under appellate consideration. The revisionary direction was therefore legally unsustainable and was quashed.
Section 271AAD authorises only the Assessing Officer, Joint Commissioner (Appeals) and Commissioner (Appeals) to initiate or impose penalty for false entries in books of account; it does not confer that power on the Principal Commissioner or Commissioner. Penalty is not automatic and requires a final determination that a false entry exists. Revisionary jurisdiction cannot be used to direct the Assessing Officer to commence section 271AAD penalty proceedings while the underlying disallowance of contract expenditure remains under appellate consideration. The revisionary direction was therefore legally unsustainable and was quashed.
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TaxTMI 
TaxTMI 
of 4918 
