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 Tribunal held that the extended reassessment period beyond three years was unavailable because the alleged escaped income related only to a claimed donation deduction and did not meet the statutory monetary threshold for extension. It further found that, even after excluding the time allowed to respond to the section 148A(b) notice, the Assessing Officer had time only until 07/04/2023 to issue the reassessment notice, but it was issued on 10/04/2023. The sixth proviso was therefore inapplicable, and the reassessment notice was time-barred and invalid; the merits of the disallowance were left open.
The Tribunal held that the extended reassessment period beyond three years was unavailable because the alleged escaped income related only to a claimed donation deduction and did not meet the statutory monetary threshold for extension. It further found that, even after excluding the time allowed to respond to the section 148A(b) notice, the Assessing Officer had time only until 07/04/2023 to issue the reassessment notice, but it was issued on 10/04/2023. The sixth proviso was therefore inapplicable, and the reassessment notice was time-barred and invalid; the merits of the disallowance were left open.
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