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...
Delay in filing the appeal against the intimation under section 143(1) was condoned because the assessee had pursued rectification and a reminder, and the time taken in that process was treated as beyond its control. Applying the principle of sufficient cause, the Tribunal held that limitation provisions should be construed liberally to advance substantial justice where there is no negligence, inaction or lack of bona fides. The order dismissing the appeal on limitation was set aside and the matter was restored for decision on merits. The connected appeal against the rectification order was dismissed as infructuous after restoration of the main appeal.
Delay in filing the appeal against the intimation under section 143(1) was condoned because the assessee had pursued rectification and a reminder, and the time taken in that process was treated as beyond its control. Applying the principle of sufficient cause, the Tribunal held that limitation provisions should be construed liberally to advance substantial justice where there is no negligence, inaction or lack of bona fides. The order dismissing the appeal on limitation was set aside and the matter was restored for decision on merits. The connected appeal against the rectification order was dismissed as infructuous after restoration of the main appeal.
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