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...
The article explains that the Finance Act 2020 amendment (effective 01.04.2020) expanded the definition of "eligible assessee" in Section 144C(15)(b) to include non-resident individuals, so the petitioner (an NRI) qualified as an eligible assessee at the time of the Section 148 notice; proceedings before the Dispute Resolution Panel under Section 144C extended limitation via Section 153, and the petitioner's post hoc Section 154 rectification was treated as an afterthought. The court found estoppel by the petitioner's conduct (including filing objections) and refused the challenge to jurisdiction absent a Transfer Order under Section 127, dismissing the writ petition.
The article explains that the Finance Act 2020 amendment (effective 01.04.2020) expanded the definition of "eligible assessee" in Section 144C(15)(b) to include non-resident individuals, so the petitioner (an NRI) qualified as an eligible assessee at the time of the Section 148 notice; proceedings before the Dispute Resolution Panel under Section 144C extended limitation via Section 153, and the petitioner's post hoc Section 154 rectification was treated as an afterthought. The court found estoppel by the petitioner's conduct (including filing objections) and refused the challenge to jurisdiction absent a Transfer Order under Section 127, dismissing the writ petition.
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