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...
Competent Authority's failure to record reasons for issuing a withholding certificate warranted corrective relief: the authority was required to assess and record prima facie nature of the transaction and address the taxpayer's contentions; in light of most payments already subjected to higher withholding and prima facie non-taxability, a directive was issued to grant a lower-rate withholding certificate for the relevant assessment year within a short timeframe, providing interim relief while preserving the Revenue's ability to conduct scrutiny assessment. The petition was partly allowed on that basis.
Competent Authority's failure to record reasons for issuing a withholding certificate warranted corrective relief: the authority was required to assess and record prima facie nature of the transaction and address the taxpayer's contentions; in light of most payments already subjected to higher withholding and prima facie non-taxability, a directive was issued to grant a lower-rate withholding certificate for the relevant assessment year within a short timeframe, providing interim relief while preserving the Revenue's ability to conduct scrutiny assessment. The petition was partly allowed on that basis.
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