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...
Reassessment under Sections 147 and 148 requires a bona fide reason to believe, founded on tangible material having a live link to possible income escapement; final proof is not required at the notice stage. Reopening is impermissible where the Assessing Officer seeks to revisit an issue consciously examined in the original scrutiny, but prior production of documents alone does not establish full and true disclosure or formation of an opinion. Survey-derived information may support reopening where it reveals previously unexamined material facts about a transaction's true character. Recorded reasons are the exclusive jurisdictional foundation: later material cannot supplement them. Taxpayers must receive the reasons, have an opportunity to object, and obtain a speaking order before reassessment proceeds.
Reassessment under Sections 147 and 148 requires a bona fide reason to believe, founded on tangible material having a live link to possible income escapement; final proof is not required at the notice stage. Reopening is impermissible where the Assessing Officer seeks to revisit an issue consciously examined in the original scrutiny, but prior production of documents alone does not establish full and true disclosure or formation of an opinion. Survey-derived information may support reopening where it reveals previously unexamined material facts about a transaction's true character. Recorded reasons are the exclusive jurisdictional foundation: later material cannot supplement them. Taxpayers must receive the reasons, have an opportunity to object, and obtain a speaking order before reassessment proceeds.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
