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...
Reassessments reopened under the income tax reassessment provision on the basis of incriminating material discovered during searches under the search provisions are excluded from the Direct Tax Vivad Se Vishwas Scheme by operation of the statutory exclusion in Section 96; where reassessment stems from search-related material the petitioner is ineligible and the court will not read temporal cut-offs or carve-outs into the statute. Clarificatory circulars identifying search-based assessments do not displace or override the statutory exclusion and cannot bring such cases within the Scheme.
Reassessments reopened under the income tax reassessment provision on the basis of incriminating material discovered during searches under the search provisions are excluded from the Direct Tax Vivad Se Vishwas Scheme by operation of the statutory exclusion in Section 96; where reassessment stems from search-related material the petitioner is ineligible and the court will not read temporal cut-offs or carve-outs into the statute. Clarificatory circulars identifying search-based assessments do not displace or override the statutory exclusion and cannot bring such cases within the Scheme.
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