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...
Condonation of delay in filing appeals against AAR orders is limited to a maximum extension of 30 days beyond the normal 30 day appeal period; the Appellate Authority (AAAR) lacks power to extend beyond that statutory window, so appeals filed beyond that limit must be rejected as time barred without consideration of merits. Rule permitting manual filing where electronic filing is prescribed does not excuse delay caused by non uploading of an order on the portal. The note also records the classificatory issue that transactions in immovable property may be outside Schedule III but treated as a service under Schedule II clause 5(e), though merits were not reached due to time bar.
Condonation of delay in filing appeals against AAR orders is limited to a maximum extension of 30 days beyond the normal 30 day appeal period; the Appellate Authority (AAAR) lacks power to extend beyond that statutory window, so appeals filed beyond that limit must be rejected as time barred without consideration of merits. Rule permitting manual filing where electronic filing is prescribed does not excuse delay caused by non uploading of an order on the portal. The note also records the classificatory issue that transactions in immovable property may be outside Schedule III but treated as a service under Schedule II clause 5(e), though merits were not reached due to time bar.
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