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...
Scrutiny assessments founded on revised returns require a statutory notice tied to the operative revised return; its absence is an incurable jurisdictional defect not cured by participation, and assessments for three years were quashed. Pre-amendment annual Form 3CL quantification could not defeat or cap weighted research-and-development deductions where substantive approval existed, but eligibility required limited verification. Rule 8D disallowance required account-based satisfaction, excluded investments yielding taxable foreign dividends, and could not automatically increase book profit under the self-contained minimum alternate tax regime. Expenditure improving access to an existing factory remained revenue expenditure where no capital asset or proprietary advantage was acquired.
Scrutiny assessments founded on revised returns require a statutory notice tied to the operative revised return; its absence is an incurable jurisdictional defect not cured by participation, and assessments for three years were quashed. Pre-amendment annual Form 3CL quantification could not defeat or cap weighted research-and-development deductions where substantive approval existed, but eligibility required limited verification. Rule 8D disallowance required account-based satisfaction, excluded investments yielding taxable foreign dividends, and could not automatically increase book profit under the self-contained minimum alternate tax regime. Expenditure improving access to an existing factory remained revenue expenditure where no capital asset or proprietary advantage was acquired.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
