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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Fair and effective opportunity of hearing in faceless reassessment requires communications to reach the assessee through its notified or registered contact details. The High Court noted that the assessee had provided an email address in its return and had another registered on the income-tax portal and MCA database, but subsequent notices were sent only to a resigned auditor's email address. As this prevented an adequate response with supporting material, the assessment order and demand notice were quashed and remanded for fresh proceedings, including a response opportunity, video-conference hearing and speaking order. The merits and validity of service under Rule 127 were left open.
Fair and effective opportunity of hearing in faceless reassessment requires communications to reach the assessee through its notified or registered contact details. The High Court noted that the assessee had provided an email address in its return and had another registered on the income-tax portal and MCA database, but subsequent notices were sent only to a resigned auditor's email address. As this prevented an adequate response with supporting material, the assessment order and demand notice were quashed and remanded for fresh proceedings, including a response opportunity, video-conference hearing and speaking order. The merits and validity of service under Rule 127 were left open.
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