Reopening Assessments invalid where satisfaction and jurisdictional approval are absent for third party seized material, leading to quashing of assess...
Benami property exclusion from the insolvency estate: Benami Act proceedings preclude IBC tribunals from reopening attachments or treating such assets...
Exclusion of limitation period: pandemic suspension plus debtor acknowledgement can extend limitation, requiring fresh factfinding on guarantee invoca...
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Revisional powers under Section 264 were held to be broad and aimed at preventing miscarriage of justice and granting relief to an assessee even where the assessee committed mistakes in the original return; consequently the revision application should have been considered and the impugned order under Section 264 was set aside. The court distinguished the Supreme Court decision in Goetze (India) Ltd., finding it inapplicable because that case did not address revisional powers under Section 264 but concerned a post filing deduction without a revised return.
Revisional powers under Section 264 were held to be broad and aimed at preventing miscarriage of justice and granting relief to an assessee even where the assessee committed mistakes in the original return; consequently the revision application should have been considered and the impugned order under Section 264 was set aside. The court distinguished the Supreme Court decision in Goetze (India) Ltd., finding it inapplicable because that case did not address revisional powers under Section 264 but concerned a post filing deduction without a revised return.
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