Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Because the assessee's returned income was below the metro-city monetary threshold in CBDT Instruction No. 1/2011, the reassessment notice under section 148 had to be issued by the ITO and not the ACIT. The Tribunal held that the ACIT lacked jurisdiction under the applicable administrative instruction, so the notice was void ab initio. As the defect went to the authority issuing the notice, the consequential reassessment proceedings were also vitiated and quashed.
Because the assessee's returned income was below the metro-city monetary threshold in CBDT Instruction No. 1/2011, the reassessment notice under section 148 had to be issued by the ITO and not the ACIT. The Tribunal held that the ACIT lacked jurisdiction under the applicable administrative instruction, so the notice was void ab initio. As the defect went to the authority issuing the notice, the consequential reassessment proceedings were also vitiated and quashed.
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