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...
Determination of proceeds of crime by calculating excess excavation as wrongful gain is upheld where documentary records and statements establish quantities beyond permitted limits; appellants failed to discharge the statutory onus to show legitimate source, so disclosed returns did not displace the calculation. Property acquired with excess income is treated as proceeds of crime, and where tainted property is not traceable the value of equivalent property (including assets purchased before the offence) may be provisionally attached subject to established safeguards and tests; provisional attachments were therefore confirmed.
Determination of proceeds of crime by calculating excess excavation as wrongful gain is upheld where documentary records and statements establish quantities beyond permitted limits; appellants failed to discharge the statutory onus to show legitimate source, so disclosed returns did not displace the calculation. Property acquired with excess income is treated as proceeds of crime, and where tainted property is not traceable the value of equivalent property (including assets purchased before the offence) may be provisionally attached subject to established safeguards and tests; provisional attachments were therefore confirmed.
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