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...
Certificate for withholding tax was set aside because the competent authority failed to consider the petitioner's submissions and relied on an AAR decision subsequently overruled by a High Court; accordingly the impugned order and certificate are quashed. The court directed issuance of a withholding tax certificate at 2% (parity with the equalization levy) as an interim measure for the relevant assessment year, to be issued within 15 days. The direction applies only to the specified year; pending appeals before the Tribunal may affect future years and the competent authority must decide subsequent applications in accordance with law.
Certificate for withholding tax was set aside because the competent authority failed to consider the petitioner's submissions and relied on an AAR decision subsequently overruled by a High Court; accordingly the impugned order and certificate are quashed. The court directed issuance of a withholding tax certificate at 2% (parity with the equalization levy) as an interim measure for the relevant assessment year, to be issued within 15 days. The direction applies only to the specified year; pending appeals before the Tribunal may affect future years and the competent authority must decide subsequent applications in accordance with law.
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