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...
Validity of assessment proceedings under section 147 turned on omission to issue statutory notice under section 143(2). The tribunal applied precedent establishing that issuance of notice under section 143(2) is mandatory where the Assessing Officer considers it necessary to verify understatement of income or underpayment of tax, and failure to issue such notice is not a curable procedural irregularity; consequence: assessments completed under section 147 read with section 144 without the mandatory notice are vitiated and the assessment orders are null and void, resulting in decision against the revenue.
Validity of assessment proceedings under section 147 turned on omission to issue statutory notice under section 143(2). The tribunal applied precedent establishing that issuance of notice under section 143(2) is mandatory where the Assessing Officer considers it necessary to verify understatement of income or underpayment of tax, and failure to issue such notice is not a curable procedural irregularity; consequence: assessments completed under section 147 read with section 144 without the mandatory notice are vitiated and the assessment orders are null and void, resulting in decision against the revenue.
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