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...
Requirement of written reasons for extension under Section 110(2) and validity of seizure raise procedural compliance and factual authenticity questions; those factual disputes-document genuineness, timelines, alleged tampering, forensic tests and mobile tower data-are for the Adjudicating Authority to determine, not for interlocutory writ relief. The High Court found no apparent reason to doubt affidavits but declined to usurp the statutory fact finding role, refused immediate release of seized goods for lack of demonstrated irreparable harm, and disposed of the writ appeal by denying interim interference with the seizure while SCN proceedings continue.
Requirement of written reasons for extension under Section 110(2) and validity of seizure raise procedural compliance and factual authenticity questions; those factual disputes-document genuineness, timelines, alleged tampering, forensic tests and mobile tower data-are for the Adjudicating Authority to determine, not for interlocutory writ relief. The High Court found no apparent reason to doubt affidavits but declined to usurp the statutory fact finding role, refused immediate release of seized goods for lack of demonstrated irreparable harm, and disposed of the writ appeal by denying interim interference with the seizure while SCN proceedings continue.
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