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...
Reopening of assessment was valid where specific information and documentary material, including affidavits and tally entries naming lenders, connected to the AOs independent formation of belief that income had escaped assessment, establishing a live link and satisfying the tangible material requirement for initiating proceedings; therefore reassessment jurisdiction was sustained. Separately, denial of opportunity to cross-examine a witness whose statement formed the basis of additions violated principles of natural justice; the impugned appellate order is set aside on that issue and the matter is remitted with direction to permit cross-examination.
Reopening of assessment was valid where specific information and documentary material, including affidavits and tally entries naming lenders, connected to the AOs independent formation of belief that income had escaped assessment, establishing a live link and satisfying the tangible material requirement for initiating proceedings; therefore reassessment jurisdiction was sustained. Separately, denial of opportunity to cross-examine a witness whose statement formed the basis of additions violated principles of natural justice; the impugned appellate order is set aside on that issue and the matter is remitted with direction to permit cross-examination.
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