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 was invalidated for lack of tangible material and the AO's independent application of mind; the notice under section 147/148 rested on 'borrowed satisfaction' from the investigation wing without requisite nexus or reasoned inference of escapement and therefore failed the four essential ingredients for reopening. On merits, share application monies treated as unexplained cash credits under section 68 were deleted: the assessee produced confirmations, bank statements and investors' audited accounts and sought summonses, and the Tribunal found the evidentiary onus discharged despite limited third party noncompliance.
Reopening of assessment was invalidated for lack of tangible material and the AO's independent application of mind; the notice under section 147/148 rested on 'borrowed satisfaction' from the investigation wing without requisite nexus or reasoned inference of escapement and therefore failed the four essential ingredients for reopening. On merits, share application monies treated as unexplained cash credits under section 68 were deleted: the assessee produced confirmations, bank statements and investors' audited accounts and sought summonses, and the Tribunal found the evidentiary onus discharged despite limited third party noncompliance.
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