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...
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A single show-cause notice or composite assessment order cannot cover multiple tax periods where separate year-wise proceedings are required under Sections 73 and 74. The notes state that an assessment covering 2017-18 and 2018-19 was therefore set aside, with liberty to commence fresh proceedings separately for each financial year, subject to the deposit condition and exclusion of time for limitation. They also record that a writ challenge to the original assessment remains maintainable despite dismissal of an appeal, so the appellate dismissal did not prevent examination of the assessment's legality. The matter was consequently remitted on the limited ground of the composite assessment.
A single show-cause notice or composite assessment order cannot cover multiple tax periods where separate year-wise proceedings are required under Sections 73 and 74. The notes state that an assessment covering 2017-18 and 2018-19 was therefore set aside, with liberty to commence fresh proceedings separately for each financial year, subject to the deposit condition and exclusion of time for limitation. They also record that a writ challenge to the original assessment remains maintainable despite dismissal of an appeal, so the appellate dismissal did not prevent examination of the assessment's legality. The matter was consequently remitted on the limited ground of the composite assessment.
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