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...
Protective additions based on seized books were set aside where corresponding substantive assessments against a third party were quashed for lack of jurisdiction and the assessing authorities had not independently examined seized material or the assessee's statements; matters remitted to the AO for fresh adjudication. The limitation challenge failed because contemporaneous records showed exchange-of-information references bringing Explanation 1(x) to section 153 into play, so the assessment was within the extended period. Approval under section 153D was held administrative; absence of elaborate reasons did not rebut the presumption of application of mind. Telescoping of admitted undisclosed income against seized cash was permitted, and complex quantification issues were remitted for recomputation with opportunity to the assessee.
Protective additions based on seized books were set aside where corresponding substantive assessments against a third party were quashed for lack of jurisdiction and the assessing authorities had not independently examined seized material or the assessee's statements; matters remitted to the AO for fresh adjudication. The limitation challenge failed because contemporaneous records showed exchange-of-information references bringing Explanation 1(x) to section 153 into play, so the assessment was within the extended period. Approval under section 153D was held administrative; absence of elaborate reasons did not rebut the presumption of application of mind. Telescoping of admitted undisclosed income against seized cash was permitted, and complex quantification issues were remitted for recomputation with opportunity to the assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
