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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Issue: Whether blocking electronic input tax credit under Rule 86A was predicated on an independent, reasoned satisfaction or on a mechanical/borrowed conclusion. Reasoning: The court held that Rule 86A requires an independent application of mind and a speaking order; reliance on the Board's Circular dated 02.11.2021 does not permit a mere mechanical exercise or borrowed satisfaction. Outcome: The tax authority was directed to pass a fresh reasoned speaking order complying with Rule 86A, and the writ was disposed. - HC
Issue: Whether blocking electronic input tax credit under Rule 86A was predicated on an independent, reasoned satisfaction or on a mechanical/borrowed conclusion. Reasoning: The court held that Rule 86A requires an independent application of mind and a speaking order; reliance on the Board's Circular dated 02.11.2021 does not permit a mere mechanical exercise or borrowed satisfaction. Outcome: The tax authority was directed to pass a fresh reasoned speaking order complying with Rule 86A, and the writ was disposed. - HC
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