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 reassessment order cannot be revised under section 263 merely because the Principal Commissioner believes further inquiry was desirable, where the Assessing Officer had examined the recorded reasons issue, considered contract notes, bank statements, computation and audited accounts, and accepted the assessee's explanation. The Tribunal held that Explanation 2 to section 263 does not apply absent a finding that the reassessment was made without any enquiry or verification. The reassessment was therefore not erroneous or prejudicial to the interests of the revenue, and the revisional jurisdiction was wrongly assumed; the revision order was quashed.
A reassessment order cannot be revised under section 263 merely because the Principal Commissioner believes further inquiry was desirable, where the Assessing Officer had examined the recorded reasons issue, considered contract notes, bank statements, computation and audited accounts, and accepted the assessee's explanation. The Tribunal held that Explanation 2 to section 263 does not apply absent a finding that the reassessment was made without any enquiry or verification. The reassessment was therefore not erroneous or prejudicial to the interests of the revenue, and the revisional jurisdiction was wrongly assumed; the revision order was quashed.
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