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...
ITAT deleted penalty under section 271D where the notice was defective and the alleged contravention did not match the penalty finally imposed: the notice referred to section 271DA read with section 269ST, while the penalty was levied for violation of section 269SS. On merits, the cash receipt formed part of a genuine sale transaction, the Revenue did not dispute that the property deal had materialised, part of the consideration had been paid through banking channels, and the tax consequences were disclosed by the assessee. The Tribunal also noted practical difficulty arising from the purchaser's non-resident status. In these circumstances, the penalty was held unsustainable.
ITAT deleted penalty under section 271D where the notice was defective and the alleged contravention did not match the penalty finally imposed: the notice referred to section 271DA read with section 269ST, while the penalty was levied for violation of section 269SS. On merits, the cash receipt formed part of a genuine sale transaction, the Revenue did not dispute that the property deal had materialised, part of the consideration had been paid through banking channels, and the tax consequences were disclosed by the assessee. The Tribunal also noted practical difficulty arising from the purchaser's non-resident status. In these circumstances, the penalty was held unsustainable.
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