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...
Revisional limitation for a Debenture Redemption Reserve adjustment to book profit runs from the original assessment where reassessment was initiated on unrelated financial transactions. The High Court held that the original assessment continues to govern matters not forming part of reassessment, while the reassessment order supersedes it only for reassessed items. Although Explanation 3 permits assessment of another escaped-income issue noticed during reassessment, the DRR issue was not shown to have arisen then. The revisional order was therefore time-barred and set aside; the merits of the DRR adjustment remained open.
Revisional limitation for a Debenture Redemption Reserve adjustment to book profit runs from the original assessment where reassessment was initiated on unrelated financial transactions. The High Court held that the original assessment continues to govern matters not forming part of reassessment, while the reassessment order supersedes it only for reassessed items. Although Explanation 3 permits assessment of another escaped-income issue noticed during reassessment, the DRR issue was not shown to have arisen then. The revisional order was therefore time-barred and set aside; the merits of the DRR adjustment remained open.
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TaxTMI 
TaxTMI 
of 4918 
