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...
Recording of a satisfaction note by the assessing officer of the searched person is a jurisdictional prerequisite to initiate proceedings and frame assessment in respect of a non-searched person under section 153C; absence of that satisfaction note vitiates jurisdiction and merits quashing of the assessment. Where limitation for an assessment year is to be computed, the relevant date is the date of satisfaction/handing over of records; applying that date, the Tribunal found the assessment year barred by limitation and quashed the assessment. The Tribunal therefore dismissed the Revenue's appeal and upheld quashing of the assessment.
Recording of a satisfaction note by the assessing officer of the searched person is a jurisdictional prerequisite to initiate proceedings and frame assessment in respect of a non-searched person under section 153C; absence of that satisfaction note vitiates jurisdiction and merits quashing of the assessment. Where limitation for an assessment year is to be computed, the relevant date is the date of satisfaction/handing over of records; applying that date, the Tribunal found the assessment year barred by limitation and quashed the assessment. The Tribunal therefore dismissed the Revenue's appeal and upheld quashing of the assessment.
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