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...
Reopening an income-tax assessment on the same factual material already forming the subject of consideration before the appellate authority was impermissible where additions originated from digital data seized during a search and used under the separate statutory provision dealing with search-derived material. The reasoning rested on the bar against initiating reassessment proceedings based on identical seized material that was under appellate scrutiny, and consequently the reopening notice was quashed, preventing further reassessment on that same material.
Reopening an income-tax assessment on the same factual material already forming the subject of consideration before the appellate authority was impermissible where additions originated from digital data seized during a search and used under the separate statutory provision dealing with search-derived material. The reasoning rested on the bar against initiating reassessment proceedings based on identical seized material that was under appellate scrutiny, and consequently the reopening notice was quashed, preventing further reassessment on that same material.
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