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...
Reassessment cannot be sustained where the reason to believe is founded on presumptions drawn from a sister concern's records rather than material showing escapement in the assessee's own case. The Court found that alleged on-money receipts were inferred by assuming a cash component in the petitioner's sales merely because another group entity faced allegations of unaccounted receipts, with only a director's profit-sharing interest and an Excel file in his Gmail account as the connecting material. The section 148 notice was quashed.
Reassessment cannot be sustained where the reason to believe is founded on presumptions drawn from a sister concern's records rather than material showing escapement in the assessee's own case. The Court found that alleged on-money receipts were inferred by assuming a cash component in the petitioner's sales merely because another group entity faced allegations of unaccounted receipts, with only a director's profit-sharing interest and an Excel file in his Gmail account as the connecting material. The section 148 notice was quashed.
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