Penalty under section 271(1)(c) deleted where income was disclosed in section 153A returns and remaining additions were only estimated or computationa...
Reopening after a scrutiny assessment was invalid where the recorded reasons incorrectly stated that the return had only been processed under limited processing and, on that false premise, invoked the deeming escapement provision. Because the original assessment had in fact been completed under scrutiny assessment, the Tribunal held that the recorded reasons disclosed clear non-application of mind. The reassessment proceedings were therefore held void ab initio, bad in law and quashed.
Reopening after a scrutiny assessment was invalid where the recorded reasons incorrectly stated that the return had only been processed under limited processing and, on that false premise, invoked the deeming escapement provision. Because the original assessment had in fact been completed under scrutiny assessment, the Tribunal held that the recorded reasons disclosed clear non-application of mind. The reassessment proceedings were therefore held void ab initio, bad in law and quashed.
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