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...
Penalty under section 271DA required a clear jurisdictional foundation in the assessment order itself, including recorded satisfaction identifying the alleged cash receipt and the ingredients of section 269ST; a bare reference to penalty proceedings was insufficient, so jurisdiction failed and the penalty order was quashed. On merits, contravention had to be proved by cogent corroborative material showing person-wise, transaction-wise or event-wise receipt beyond the statutory threshold; uncorroborated tally data, statements and estimated income from rejected books did not discharge the Revenue's burden, so the penalty was deleted.
Penalty under section 271DA required a clear jurisdictional foundation in the assessment order itself, including recorded satisfaction identifying the alleged cash receipt and the ingredients of section 269ST; a bare reference to penalty proceedings was insufficient, so jurisdiction failed and the penalty order was quashed. On merits, contravention had to be proved by cogent corroborative material showing person-wise, transaction-wise or event-wise receipt beyond the statutory threshold; uncorroborated tally data, statements and estimated income from rejected books did not discharge the Revenue's burden, so the penalty was deleted.
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