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...
Mandatory statutory notice prior to framing an assessment is required even where a return is filed in response to a notice under reassessment proceedings; if the Assessing Officer takes the filed return as the starting point for computation and acts upon it, pending electronic verification or later submission of a manual verification does not alone invalidate the return. An assessment completed without issuing the mandatory notice under the statutory provision governing notice before assessment is a jurisdictional defect and vitiates the assessment framed under reassessment provisions, resulting in the quashing of the assessment for the relevant year.
Mandatory statutory notice prior to framing an assessment is required even where a return is filed in response to a notice under reassessment proceedings; if the Assessing Officer takes the filed return as the starting point for computation and acts upon it, pending electronic verification or later submission of a manual verification does not alone invalidate the return. An assessment completed without issuing the mandatory notice under the statutory provision governing notice before assessment is a jurisdictional defect and vitiates the assessment framed under reassessment provisions, resulting in the quashing of the assessment for the relevant year.
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