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...
Authorities disallowed purchases as 'bogus' on the premise that the assessee failed to prove genuineness, but ignored extensive documentary material (confirmations, bills, lorry receipts, ledgers, bank statements, returns and accounts) filed during assessment. The decision emphasises that where authorities record a factual finding of non-production yet fail to consider or verify available documents, the audi alteram partem principle and statutory duty to evaluate submissions are breached; accordingly the impugned disallowance cannot stand and the addition was set aside and deleted for want of proper verification and consideration.
Authorities disallowed purchases as 'bogus' on the premise that the assessee failed to prove genuineness, but ignored extensive documentary material (confirmations, bills, lorry receipts, ledgers, bank statements, returns and accounts) filed during assessment. The decision emphasises that where authorities record a factual finding of non-production yet fail to consider or verify available documents, the audi alteram partem principle and statutory duty to evaluate submissions are breached; accordingly the impugned disallowance cannot stand and the addition was set aside and deleted for want of proper verification and consideration.
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