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...
Section 153C jurisdiction is treated as constructively satisfied where the same Assessing Officer handles the searched person and the other person, so physical handover of seized material is not essential once the officer applies his mind. One consolidated satisfaction note can cover the six-year block under sections 153C and 153A, and an Investigation Wing trigger is not fatal by itself. On limitation, the assessments were time-barred because the relevant date, whether taken as the search, constructive handover, conclusion of Settlement Commission proceedings, or recording of satisfaction, placed the proceedings outside the statutory period. Additions based on uncorroborated third-party excel sheets were unsustainable where identity was doubtful and cross-examination was denied.
Section 153C jurisdiction is treated as constructively satisfied where the same Assessing Officer handles the searched person and the other person, so physical handover of seized material is not essential once the officer applies his mind. One consolidated satisfaction note can cover the six-year block under sections 153C and 153A, and an Investigation Wing trigger is not fatal by itself. On limitation, the assessments were time-barred because the relevant date, whether taken as the search, constructive handover, conclusion of Settlement Commission proceedings, or recording of satisfaction, placed the proceedings outside the statutory period. Additions based on uncorroborated third-party excel sheets were unsustainable where identity was doubtful and cross-examination was denied.
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