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...
When a filed return is selected for scrutiny, the scope is ordinarily limited to verifying and disallowing claims and does not permit the Assessing Officer to reduce income voluntarily admitted by the taxpayer; statutory remedies exist to correct any erroneous admission but were not availed here. Circulars relied upon did not require reversion of a voluntarily declared return. A post-survey voluntary declaration incorporated in a later return and not retracted or revised under the Act was treated as conscious admission; the burden to prove evidentiary basis does not shift to the Assessing Officer. Tribunal factual findings upheld; taxpayer appeal dismissed.
When a filed return is selected for scrutiny, the scope is ordinarily limited to verifying and disallowing claims and does not permit the Assessing Officer to reduce income voluntarily admitted by the taxpayer; statutory remedies exist to correct any erroneous admission but were not availed here. Circulars relied upon did not require reversion of a voluntarily declared return. A post-survey voluntary declaration incorporated in a later return and not retracted or revised under the Act was treated as conscious admission; the burden to prove evidentiary basis does not shift to the Assessing Officer. Tribunal factual findings upheld; taxpayer appeal dismissed.
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