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...
Cessation of liability under tax law was not attracted where long-standing foreign trade creditors remained recorded as liabilities and were not written off in the year under review; alleged waivers were reflected and offered to tax only in a later year. The legal principle applied required a cessation of liability in the year and a corresponding benefit to the taxpayer in cash, kind or otherwise; absent evidence that liabilities ceased or that the taxpayer became richer by remission during the year, the prior addition under the cessation rule was deleted.
Cessation of liability under tax law was not attracted where long-standing foreign trade creditors remained recorded as liabilities and were not written off in the year under review; alleged waivers were reflected and offered to tax only in a later year. The legal principle applied required a cessation of liability in the year and a corresponding benefit to the taxpayer in cash, kind or otherwise; absent evidence that liabilities ceased or that the taxpayer became richer by remission during the year, the prior addition under the cessation rule was deleted.
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