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...
Quashing of the administrative order was ordered subject to the petitioner depositing the full contested liability within two weeks as an undertaking; the authority must thereafter provide an opportunity of hearing, consider the petitioner's reply and written submissions, and undertake fresh adjudication. The court set aside the impugned Order-in-Original and permitted the petition partly, with the deposited amount to be refunded or adjusted as appropriate after the re-adjudication. The relief granted was conditional on the undertaking to deposit and did not preclude remand for fresh decision-making.
Quashing of the administrative order was ordered subject to the petitioner depositing the full contested liability within two weeks as an undertaking; the authority must thereafter provide an opportunity of hearing, consider the petitioner's reply and written submissions, and undertake fresh adjudication. The court set aside the impugned Order-in-Original and permitted the petition partly, with the deposited amount to be refunded or adjusted as appropriate after the re-adjudication. The relief granted was conditional on the undertaking to deposit and did not preclude remand for fresh decision-making.
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