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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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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