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...
Transfer and revision proceedings were held unsustainable where the assessee's objections were not followed by an effective hearing, and the revision record itself showed same-day show cause notices carrying different hearing dates without a plausible explanation. The court found that both the transfer order and the consequential revision order were passed in undue haste during the peak COVID period, when business operations and movement were severely restricted. Both orders were set aside for breach of natural justice and denial of a fair and reasonable opportunity of hearing, with liberty to initiate fresh proceedings in accordance with law.
Transfer and revision proceedings were held unsustainable where the assessee's objections were not followed by an effective hearing, and the revision record itself showed same-day show cause notices carrying different hearing dates without a plausible explanation. The court found that both the transfer order and the consequential revision order were passed in undue haste during the peak COVID period, when business operations and movement were severely restricted. Both orders were set aside for breach of natural justice and denial of a fair and reasonable opportunity of hearing, with liberty to initiate fresh proceedings in accordance with law.
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