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 assessments based on documents found during a search must respect the ten-year limitation applicable to reassessments under the tax statute; the High Court found that treating the search date and subsequent assessment year calculation rendered the impugned reopening for the earlier assessment year beyond the permissible ten years and therefore invalid, and quashed the reopening for that year. The Court held that the limitation point is a pure question of statutory interpretation that may be raised at any stage and exercised its writ jurisdiction to set aside the reassessment initiated in breach of the limitation rule.
Reopening assessments based on documents found during a search must respect the ten-year limitation applicable to reassessments under the tax statute; the High Court found that treating the search date and subsequent assessment year calculation rendered the impugned reopening for the earlier assessment year beyond the permissible ten years and therefore invalid, and quashed the reopening for that year. The Court held that the limitation point is a pure question of statutory interpretation that may be raised at any stage and exercised its writ jurisdiction to set aside the reassessment initiated in breach of the limitation rule.
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