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...
Reopening of assessment was quashed where the AO relied uncritically on AIR information without independent application of mind; the statutory test requires information with a direct nexus to form a belief that income escaped assessment, and treating transmission as conclusive or assuming return was not filed vitiated the formation of belief. The Addl. CIT's approval was held mechanical and based on incomplete facts, and the appellate tribunal upheld CIT(A)'s decision to quash the reopening, deciding against the revenue.
Reopening of assessment was quashed where the AO relied uncritically on AIR information without independent application of mind; the statutory test requires information with a direct nexus to form a belief that income escaped assessment, and treating transmission as conclusive or assuming return was not filed vitiated the formation of belief. The Addl. CIT's approval was held mechanical and based on incomplete facts, and the appellate tribunal upheld CIT(A)'s decision to quash the reopening, deciding against the revenue.
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