Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
Revision under section 263 challenged the validity of an exemption claim under section 54 on grounds that the assessing officer failed to examine supporting materials; tribunal found the AO had issued a specific query under section 142(1), the assessee uploaded conveyance deed and supporting evidence in response, and assessment followed that examination. Consequently the reassessment order under section 263 was not sustainable because the assessment was not shown to be erroneous or prejudicial where relevant details were on record and considered. Reliance was placed on prior judicial authority supporting that record-based examination negates the ground for revision.
Revision under section 263 challenged the validity of an exemption claim under section 54 on grounds that the assessing officer failed to examine supporting materials; tribunal found the AO had issued a specific query under section 142(1), the assessee uploaded conveyance deed and supporting evidence in response, and assessment followed that examination. Consequently the reassessment order under section 263 was not sustainable because the assessment was not shown to be erroneous or prejudicial where relevant details were on record and considered. Reliance was placed on prior judicial authority supporting that record-based examination negates the ground for revision.
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