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 under Section 147 before the 01.04.2021 amendments requires only that the notice under Section 148 be issued within the limitation period; service within that period is not a jurisdictional prerequisite. The date of dispatch governs validity of issuance, so a notice issued on 31.03.2019 remains effective even if actual service occurred later. Applying that rule, the reassessment proceedings were not vitiated by delayed service or an accompanying attachment error, and the writ challenging the reassessment was dismissed.
Reopening of assessment under Section 147 before the 01.04.2021 amendments requires only that the notice under Section 148 be issued within the limitation period; service within that period is not a jurisdictional prerequisite. The date of dispatch governs validity of issuance, so a notice issued on 31.03.2019 remains effective even if actual service occurred later. Applying that rule, the reassessment proceedings were not vitiated by delayed service or an accompanying attachment error, and the writ challenging the reassessment was dismissed.
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