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...
The HC held that reassessment proceedings for Assessment Year 2015-16 were governed by the amended limitation regime under section 149 effective from 01.09.2024. A notice issued under section 148 beyond three years from the end of the relevant assessment year was without jurisdiction unless the conditions in section 149(1)(b) were satisfied. As no material showed that escaped income met the statutory threshold for invoking the extended period, the jurisdictional basis for reassessment failed. The show-cause notice under section 148A(b), the order under section 148A(d), and the notice under section 148 were quashed.
The HC held that reassessment proceedings for Assessment Year 2015-16 were governed by the amended limitation regime under section 149 effective from 01.09.2024. A notice issued under section 148 beyond three years from the end of the relevant assessment year was without jurisdiction unless the conditions in section 149(1)(b) were satisfied. As no material showed that escaped income met the statutory threshold for invoking the extended period, the jurisdictional basis for reassessment failed. The show-cause notice under section 148A(b), the order under section 148A(d), and the notice under section 148 were quashed.
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