Tax Reassessment and Penalties: Original Conclusion Prevails Despite Transaction Clarity u/ss 147, 271D, and 271E.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Reopening of assessment u/s 147 - ‘loan given” was believed to be undisclosed income of assessee - penalty u/s 271D and 271E - the “original-conclusion” was not faulty at the time of initiating re-assessment / passing of order of reassessment / launching of penalty-proceedings. It is a subsequent matter that the dust was clear about the nature of transaction and “original-conclusion” was reversed. Hence, it would be apt to give preference to the “original-conclusion” which has set the proceedings in motion. - AT....