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...
In absence of a recorded satisfaction note by Revenue, the notice date (27.05.2022) was treated as the deemed date of search for the non-searched person, fixing the deemed year of search as F.Y. 2022-23 (A.Y. 2023-24) and thus establishing the ten-year limitation block from A.Y. 2023-24 back to A.Y. 2014-15; because A.Y. 2012-13 fell outside that block the Assessing Officer lacked jurisdiction under section 153C and the assessment framed on 03.02.2023 was time-barred and was quashed, with other grounds left open.
In absence of a recorded satisfaction note by Revenue, the notice date (27.05.2022) was treated as the deemed date of search for the non-searched person, fixing the deemed year of search as F.Y. 2022-23 (A.Y. 2023-24) and thus establishing the ten-year limitation block from A.Y. 2023-24 back to A.Y. 2014-15; because A.Y. 2012-13 fell outside that block the Assessing Officer lacked jurisdiction under section 153C and the assessment framed on 03.02.2023 was time-barred and was quashed, with other grounds left open.
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