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...
In writ proceedings, a taxpayer who received a show cause notice alleging wilful suppression and invoking Section 74, but filed no reply, made payment without protest, and accepted before the adjudicating authority that tax, interest and penalty would be paid, was held estopped from taking a contrary stand later. The Court treated the recorded admission and unchallenged adjudication note as decisive, and held that prior voluntary payment after audit detection did not by itself defeat Section 74 where the allegation of suppression remained uncontested. On that basis, no interference under Article 226 was made and the writ challenge failed.
In writ proceedings, a taxpayer who received a show cause notice alleging wilful suppression and invoking Section 74, but filed no reply, made payment without protest, and accepted before the adjudicating authority that tax, interest and penalty would be paid, was held estopped from taking a contrary stand later. The Court treated the recorded admission and unchallenged adjudication note as decisive, and held that prior voluntary payment after audit detection did not by itself defeat Section 74 where the allegation of suppression remained uncontested. On that basis, no interference under Article 226 was made and the writ challenge failed.
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