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...
Penalty under section 271D was held impermissible while the assessment order was under challenge before a statutory appellate forum; the court reasoned that penalty proceedings should be kept in abeyance pending the outcome of quantum proceedings and accordingly set aside the impugned penalty order. The court relied on prior precedent to conclude that initiation or finalisation of penalty proceedings during subsistence of a quantum appeal defeats orderly adjudication; consequence: penalty order dated 9 December 2025 was quashed and penalty proceedings directed to be stayed until the quantum appeal is decided.
Penalty under section 271D was held impermissible while the assessment order was under challenge before a statutory appellate forum; the court reasoned that penalty proceedings should be kept in abeyance pending the outcome of quantum proceedings and accordingly set aside the impugned penalty order. The court relied on prior precedent to conclude that initiation or finalisation of penalty proceedings during subsistence of a quantum appeal defeats orderly adjudication; consequence: penalty order dated 9 December 2025 was quashed and penalty proceedings directed to be stayed until the quantum appeal is decided.
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