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...
Estimation of profit element in non-genuine purchases: the Tribunal held that the CIT(A) mechanically followed an earlier ITAT direction limiting disallowance without independently verifying factual parity between years or the effect of later binding precedents, and that subsequent authority criticises fixed-rate profit estimates where the assessee fails to prove genuineness. The impugned restriction was set aside and the matter remitted to the CIT(A) to re-adjudicate after affording the assessee a hearing, to apply relevant binding precedents and record a reasoned finding. The Revenue's appeal was allowed for statistical purposes and remand ordered.
Estimation of profit element in non-genuine purchases: the Tribunal held that the CIT(A) mechanically followed an earlier ITAT direction limiting disallowance without independently verifying factual parity between years or the effect of later binding precedents, and that subsequent authority criticises fixed-rate profit estimates where the assessee fails to prove genuineness. The impugned restriction was set aside and the matter remitted to the CIT(A) to re-adjudicate after affording the assessee a hearing, to apply relevant binding precedents and record a reasoned finding. The Revenue's appeal was allowed for statistical purposes and remand ordered.
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