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...
After the 01.04.1989 amendment, delayed payment of self-assessment tax under section 140A(3) no longer attracted penalty; the provision treated the assessee as in default only for recovery of unpaid tax and interest. In the absence of any corresponding expansion of section 221(1), penalty could not be imposed for such default under section 140A(3) read with section 221(1). The Tribunal therefore held the penalty unsustainable in law and directed its deletion. The issue of sufficient cause for the delay became academic once statutory authority for the penalty itself was lacking.
After the 01.04.1989 amendment, delayed payment of self-assessment tax under section 140A(3) no longer attracted penalty; the provision treated the assessee as in default only for recovery of unpaid tax and interest. In the absence of any corresponding expansion of section 221(1), penalty could not be imposed for such default under section 140A(3) read with section 221(1). The Tribunal therefore held the penalty unsustainable in law and directed its deletion. The issue of sufficient cause for the delay became academic once statutory authority for the penalty itself was lacking.
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