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...
Extraordinary delay in filing revisions was not condoned because the explanation of wrong legal advice and bona fide misconception was contrary to the record and did not satisfy "sufficient cause"; the revisions against conviction were dismissed as time-barred. The settlement agreement did not extinguish the pending Section 138 complaints because withdrawal was expressly conditional on full payment, and default kept the complainant's right to proceed alive; quashing was refused. Civil execution and criminal cheque-dishonour proceedings were held to operate in distinct fields, so double jeopardy did not apply and probation was declined. Earlier and later payments were credited while computing liability, leading only to a limited reduction in fine.
Extraordinary delay in filing revisions was not condoned because the explanation of wrong legal advice and bona fide misconception was contrary to the record and did not satisfy "sufficient cause"; the revisions against conviction were dismissed as time-barred. The settlement agreement did not extinguish the pending Section 138 complaints because withdrawal was expressly conditional on full payment, and default kept the complainant's right to proceed alive; quashing was refused. Civil execution and criminal cheque-dishonour proceedings were held to operate in distinct fields, so double jeopardy did not apply and probation was declined. Earlier and later payments were credited while computing liability, leading only to a limited reduction in fine.
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