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...
Where sales were fully recorded in the assessee's books and there was no evidence of suppressed sales, a separate 6% profit addition on those sales was impermissible even though the counterparties were alleged bogus entities. The Tribunal had sustained addition only on the bogus purchases, and no material displaced that factual basis. The Assessing Officer had not recorded any finding that the sales themselves were bogus or that a further sales addition was warranted. The HC therefore dismissed the revenue's appeals and upheld rejection of the further profit addition.
Where sales were fully recorded in the assessee's books and there was no evidence of suppressed sales, a separate 6% profit addition on those sales was impermissible even though the counterparties were alleged bogus entities. The Tribunal had sustained addition only on the bogus purchases, and no material displaced that factual basis. The Assessing Officer had not recorded any finding that the sales themselves were bogus or that a further sales addition was warranted. The HC therefore dismissed the revenue's appeals and upheld rejection of the further profit addition.
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