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...
Sale advances supported by a seized agreement, receipt and subsequent conveyance were treated as explained sale consideration rather than unexplained money under section 69A. The notes state that any suppressed consideration would instead be considered under capital gains in the relevant assessment year, and the section 69A additions were vacated. For section 153C, the relevant date for exclusion is stated to be the search initiation date, not later receipt of seized material; the deeming provision is confined to identifying abated assessment years, so the jurisdictional challenge failed. The mechanical-approval challenge under section 153D also failed for lack of cogent supporting material. The consolidated satisfaction-note issue remained open.
Sale advances supported by a seized agreement, receipt and subsequent conveyance were treated as explained sale consideration rather than unexplained money under section 69A. The notes state that any suppressed consideration would instead be considered under capital gains in the relevant assessment year, and the section 69A additions were vacated. For section 153C, the relevant date for exclusion is stated to be the search initiation date, not later receipt of seized material; the deeming provision is confined to identifying abated assessment years, so the jurisdictional challenge failed. The mechanical-approval challenge under section 153D also failed for lack of cogent supporting material. The consolidated satisfaction-note issue remained open.
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