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...
Penalty for cash receipts is attracted only when the receipt falls within one of the three statutory situations under section 269ST: receipt from a person in a day, receipt for a single transaction, or receipt relating to one event or occasion. The note explains that admitted cash sales, or an assessment completed by estimating profit on those sales, are not enough by themselves; the penalty order must record facts showing the specific statutory breach. In the absence of such findings, levy of penalty under section 271DA is unjustified, and the same reasoning applies where the facts and issue are identical across years.
Penalty for cash receipts is attracted only when the receipt falls within one of the three statutory situations under section 269ST: receipt from a person in a day, receipt for a single transaction, or receipt relating to one event or occasion. The note explains that admitted cash sales, or an assessment completed by estimating profit on those sales, are not enough by themselves; the penalty order must record facts showing the specific statutory breach. In the absence of such findings, levy of penalty under section 271DA is unjustified, and the same reasoning applies where the facts and issue are identical across years.
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