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...
An assessment made as a consequential order under the revision mechanism does not survive once the underlying revision orders are set aside and remitted for fresh consideration. Here, the Tribunal held that the assessment passed under sections 147, 263 and 144B depended entirely on section 263 orders that had already been sent back to the Principal Commissioner for a fresh order. Because that foundation had ceased to exist, the assessment order and the appellate order affirming it were treated as infructuous, and the appeals were dismissed on that basis.
An assessment made as a consequential order under the revision mechanism does not survive once the underlying revision orders are set aside and remitted for fresh consideration. Here, the Tribunal held that the assessment passed under sections 147, 263 and 144B depended entirely on section 263 orders that had already been sent back to the Principal Commissioner for a fresh order. Because that foundation had ceased to exist, the assessment order and the appellate order affirming it were treated as infructuous, and the appeals were dismissed on that basis.
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