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 107(4) permits a discretionary additional thirty days beyond the primary ninety-day limitation if the appellant shows sufficient cause, and that discretionary period is exhaustive; courts constitutional writ jurisdiction cannot be used to further extend the statutory timeline beyond the total 120 days. Reasons not meeting the sufficient cause standard will not support condonation. Where an alternative efficacious remedy in the statute has been availed, the validity of the original demand order cannot be re-opened via a collateral constitutional challenge. Taxing statutes operate within strict time frames, placing a duty on taxpayers to monitor proceedings and verify orders on the portal.
Section 107(4) permits a discretionary additional thirty days beyond the primary ninety-day limitation if the appellant shows sufficient cause, and that discretionary period is exhaustive; courts constitutional writ jurisdiction cannot be used to further extend the statutory timeline beyond the total 120 days. Reasons not meeting the sufficient cause standard will not support condonation. Where an alternative efficacious remedy in the statute has been availed, the validity of the original demand order cannot be re-opened via a collateral constitutional challenge. Taxing statutes operate within strict time frames, placing a duty on taxpayers to monitor proceedings and verify orders on the portal.
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