Human-probability test defeats political donation deductions where banking records mask accommodation-entry fund layering rather than genuine contribu...
Reassessment proceedings under sections 148A(3) and 148 require the assessing officer to examine the taxpayer's explanation and supporting records before concluding that reassessment is warranted. Bank credits asserted to be disclosed capital transactions or other non-turnover receipts must be considered, including balance-sheet disclosures. Where those materials are not examined, and no clarification is sought regarding the absence of increased capital or unsecured loans, the conclusion lacks cogent reasons. The reassessment order and consequential notice were quashed, with reconsideration directed after examining the explanation and obtaining any necessary clarification.
Reassessment proceedings under sections 148A(3) and 148 require the assessing officer to examine the taxpayer's explanation and supporting records before concluding that reassessment is warranted. Bank credits asserted to be disclosed capital transactions or other non-turnover receipts must be considered, including balance-sheet disclosures. Where those materials are not examined, and no clarification is sought regarding the absence of increased capital or unsecured loans, the conclusion lacks cogent reasons. The reassessment order and consequential notice were quashed, with reconsideration directed after examining the explanation and obtaining any necessary clarification.
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