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...
Penalty under section 271D cannot survive once the reassessment orders and the recorded satisfaction forming its basis are quashed, because the alleged section 269SS violation loses its substratum. The Tribunal also held that levy of penalty requires reliable independent evidence of actual acceptance of cash loans or deposits; third-party statements and alleged coded entries, without corroboration in the assessee's books or other incriminating material, were insufficient. As the related additions had already been deleted and no separate proof of cash borrowing was established, the penalties for both assessment years were held unsustainable and directed to be deleted.
Penalty under section 271D cannot survive once the reassessment orders and the recorded satisfaction forming its basis are quashed, because the alleged section 269SS violation loses its substratum. The Tribunal also held that levy of penalty requires reliable independent evidence of actual acceptance of cash loans or deposits; third-party statements and alleged coded entries, without corroboration in the assessee's books or other incriminating material, were insufficient. As the related additions had already been deleted and no separate proof of cash borrowing was established, the penalties for both assessment years were held unsustainable and directed to be deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4814 
Join Channel 
