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...
Reopening of assessment must be confined to the income that formed the assessing officer's belief; other income noticed during reassessment may be assessed only if the originally alleged escaped income remains assessed as escaped. Applying the jurisdictional precedent, where the AO after issuing a notice accepts the returned income on the issue that prompted reopening, the AO cannot independently compute deemed income based on book profit or levy MAT in that reassessment without issuing a fresh notice. Consequently the MAT computation in the reassessment was quashed as beyond the scope of proceedings.
Reopening of assessment must be confined to the income that formed the assessing officer's belief; other income noticed during reassessment may be assessed only if the originally alleged escaped income remains assessed as escaped. Applying the jurisdictional precedent, where the AO after issuing a notice accepts the returned income on the issue that prompted reopening, the AO cannot independently compute deemed income based on book profit or levy MAT in that reassessment without issuing a fresh notice. Consequently the MAT computation in the reassessment was quashed as beyond the scope of proceedings.
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