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...
Provisional attachment of the property was confirmed under the PBPT Act as the transaction falls within the scope of benami property under Section 2(9)(A); the appellant failed to explain sources of funds, did not produce original lease evidence and adverse inference was drawn for non-production, supporting IO findings of fabrication. Beneficial ownership remains under investigation-IO to re-investigate whether the beneficial owner includes the named individual, his son, and/or a company-so the property is not to be released. The Tribunal may modify AA orders under Section 46(4)(e); appeal by the benamidar is dismissed.
Provisional attachment of the property was confirmed under the PBPT Act as the transaction falls within the scope of benami property under Section 2(9)(A); the appellant failed to explain sources of funds, did not produce original lease evidence and adverse inference was drawn for non-production, supporting IO findings of fabrication. Beneficial ownership remains under investigation-IO to re-investigate whether the beneficial owner includes the named individual, his son, and/or a company-so the property is not to be released. The Tribunal may modify AA orders under Section 46(4)(e); appeal by the benamidar is dismissed.
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