Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Extended period of limitation unsustainable; allowable deductions for prompt payment discounts, pro rata recovery, freight and VAT led to demand being...
ITAT held that reassessment jurisdiction was vitiated because the approval for reopening reflected clear non-application of mind. The Assessing Officer's proposal referred to section 147(b), a provision that had ceased to exist, and the sanctioning authority issued only a ritualistic, mechanical approval under section 151 without correcting the obvious errors. On that jurisdictional defect, the reopening was quashed and the assessee's legal grounds were allowed. The merits of the addition were left open and were not adjudicated.
ITAT held that reassessment jurisdiction was vitiated because the approval for reopening reflected clear non-application of mind. The Assessing Officer's proposal referred to section 147(b), a provision that had ceased to exist, and the sanctioning authority issued only a ritualistic, mechanical approval under section 151 without correcting the obvious errors. On that jurisdictional defect, the reopening was quashed and the assessee's legal grounds were allowed. The merits of the addition were left open and were not adjudicated.
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