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...
Section 172 assessment procedures are examined where a shipping assessee elected annual assessment of total income under Section 172(7), while separate vessel-wise assessments were also made under Section 172(4). The notes identify the contention that, after exercising the annual-assessment option, separate assessments for individual vessels should not proceed. They also record that a return processed under Section 143(1), resulting in a refund, had become final. The High Court found the issues arguable and granted interim protection by staying recovery under the Section 172(4) assessments pending final disposal of the writ petition.
Section 172 assessment procedures are examined where a shipping assessee elected annual assessment of total income under Section 172(7), while separate vessel-wise assessments were also made under Section 172(4). The notes identify the contention that, after exercising the annual-assessment option, separate assessments for individual vessels should not proceed. They also record that a return processed under Section 143(1), resulting in a refund, had become final. The High Court found the issues arguable and granted interim protection by staying recovery under the Section 172(4) assessments pending final disposal of the writ petition.
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