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...
Rule 86A permits blocking of input tax credit only when there is adequate material supporting reasons to believe that credit was fraudulently availed or otherwise ineligible, and a revocation representation must be decided by a reasoned speaking order. On the facts discussed, the blockage was sustained because the order recorded that the suppliers lacked physical infrastructure, CCTV verification did not show vehicle movement, and inward slips suggested manipulation of records. The restriction was confined to credit linked to the questioned transactions and was found not disproportionate, though the Revenue was expected to pursue the consequential show-cause and adjudication without delay.
Rule 86A permits blocking of input tax credit only when there is adequate material supporting reasons to believe that credit was fraudulently availed or otherwise ineligible, and a revocation representation must be decided by a reasoned speaking order. On the facts discussed, the blockage was sustained because the order recorded that the suppliers lacked physical infrastructure, CCTV verification did not show vehicle movement, and inward slips suggested manipulation of records. The restriction was confined to credit linked to the questioned transactions and was found not disproportionate, though the Revenue was expected to pursue the consequential show-cause and adjudication without delay.
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