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...
A scrutiny assessment challenge based on alleged non-compliance with CBDT scrutiny-selection instructions was rejected, the Tribunal following binding jurisdictional High Court precedent. The rent-related disallowance under section 40(a)(ia) was deleted to the extent tax was not deductible, including rent paid to Haryana Urban Development Authority. In the bogus purchase dispute, the Tribunal upheld partial relief and gross profit estimation at 2.37% on market-comparable reasoning, and applied the same approach to the connected unexplained expenditure issue. The estimated addition on sundry creditors was rejected because no individual credit entries were examined and the purchases stood accepted. The related-party salary disallowance under section 40A(2)(b) was also upheld as deleted on revenue-neutrality grounds.
A scrutiny assessment challenge based on alleged non-compliance with CBDT scrutiny-selection instructions was rejected, the Tribunal following binding jurisdictional High Court precedent. The rent-related disallowance under section 40(a)(ia) was deleted to the extent tax was not deductible, including rent paid to Haryana Urban Development Authority. In the bogus purchase dispute, the Tribunal upheld partial relief and gross profit estimation at 2.37% on market-comparable reasoning, and applied the same approach to the connected unexplained expenditure issue. The estimated addition on sundry creditors was rejected because no individual credit entries were examined and the purchases stood accepted. The related-party salary disallowance under section 40A(2)(b) was also upheld as deleted on revenue-neutrality grounds.
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