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...
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Carry forward and set off of short-term capital loss depends on compliance with the prescribed time limit for filing the loss return; where the return for AY 2020-21 was filed beyond the due date and no extension or condonation was sought, the Tribunal stated that carry forward stood denied when the return was processed. It further stated that the earlier denial could not be reopened in an appeal for AY 2024-25, so capital gains of that year could not be set off against the carried forward loss. The Tribunal distinguished Kullu Valley Transport Co. on facts and upheld the denial of set off.
Carry forward and set off of short-term capital loss depends on compliance with the prescribed time limit for filing the loss return; where the return for AY 2020-21 was filed beyond the due date and no extension or condonation was sought, the Tribunal stated that carry forward stood denied when the return was processed. It further stated that the earlier denial could not be reopened in an appeal for AY 2024-25, so capital gains of that year could not be set off against the carried forward loss. The Tribunal distinguished Kullu Valley Transport Co. on facts and upheld the denial of set off.
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