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...
Revisionary review under section 263 was considered on whether the AO failed to inquire into the source of share capital and whether acceptance of a merchant banker valuation was erroneous. The tribunal found the AO had the investor's balance sheet before him, accepted the investor's creditworthiness, and that mere suspicion or association with a group did not amount to lack of inquiry. Inquiry into the source-of-source was not required, and the AO properly accepted a DCF valuation by a qualified merchant banker; revisionary interference was unwarranted and decision favoured the assessee.
Revisionary review under section 263 was considered on whether the AO failed to inquire into the source of share capital and whether acceptance of a merchant banker valuation was erroneous. The tribunal found the AO had the investor's balance sheet before him, accepted the investor's creditworthiness, and that mere suspicion or association with a group did not amount to lack of inquiry. Inquiry into the source-of-source was not required, and the AO properly accepted a DCF valuation by a qualified merchant banker; revisionary interference was unwarranted and decision favoured the assessee.
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