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...
The issue concerns whether an Assessing Officer may rely on a Valuation Officer (DVO) report delivered after the six month deadline in section 142A(6) to invoke the exclusion period under Explanation 1(v) to section 153 and thereby extend limitation. The HC agreed with the Tribunal that section 142A(6) requires the report within six months and that the exclusion-period and its proviso apply only where the report falls within that regime; a belated DVO report has no legal value to extend limitation, and the Principal Commissioner was not justified in revising the assessment under revision powers. Revenue appeal dismissed.
The issue concerns whether an Assessing Officer may rely on a Valuation Officer (DVO) report delivered after the six month deadline in section 142A(6) to invoke the exclusion period under Explanation 1(v) to section 153 and thereby extend limitation. The HC agreed with the Tribunal that section 142A(6) requires the report within six months and that the exclusion-period and its proviso apply only where the report falls within that regime; a belated DVO report has no legal value to extend limitation, and the Principal Commissioner was not justified in revising the assessment under revision powers. Revenue appeal dismissed.
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