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...
The statutory right of appeal is order-specific: an assessee may challenge only the order that creates a grievance, and an intimation under section 143(1) and an assessment under section 143(3) operate independently. Where the later assessment merely accepts the income already determined under section 143(1) and makes no fresh addition or other adverse variation, no grievance arises from that assessment order and no appeal lies against it. The Tribunal rejected the doctrine of merger, holding that a challenge to adjustments made under section 143(1) must be taken against that order itself, not indirectly through an appeal against the later assessment. The dismissal of the appeal was therefore upheld.
The statutory right of appeal is order-specific: an assessee may challenge only the order that creates a grievance, and an intimation under section 143(1) and an assessment under section 143(3) operate independently. Where the later assessment merely accepts the income already determined under section 143(1) and makes no fresh addition or other adverse variation, no grievance arises from that assessment order and no appeal lies against it. The Tribunal rejected the doctrine of merger, holding that a challenge to adjustments made under section 143(1) must be taken against that order itself, not indirectly through an appeal against the later assessment. The dismissal of the appeal was therefore upheld.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4817 
Join Channel 
