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...
The dispute concerns validity of an assessment order issued by an Assessing Officer who lacked jurisdiction due to multiple transfers of PAN jurisdiction; absence of any transfer order under the relevant statutory power prior to assessment meant jurisdiction remained with the original ITO. The tribunal applied the principle that an order by a non jurisdictional Assessing Officer is void ab initio and that jurisdiction cannot be conferred by the assessee's participation; accordingly the assessment was held void and the appellate order upholding it could not stand, appeal allowed.
The dispute concerns validity of an assessment order issued by an Assessing Officer who lacked jurisdiction due to multiple transfers of PAN jurisdiction; absence of any transfer order under the relevant statutory power prior to assessment meant jurisdiction remained with the original ITO. The tribunal applied the principle that an order by a non jurisdictional Assessing Officer is void ab initio and that jurisdiction cannot be conferred by the assessee's participation; accordingly the assessment was held void and the appellate order upholding it could not stand, appeal allowed.
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