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...
Section 144C(13) imposes an imperative one month deadline to complete assessments in conformity with Dispute Resolution Panel directions; failure to pass a final order within that period renders the assessing authority functus officio and deprives it of jurisdiction, so a draft assessment order and any notice of demand issued with it do not create an enforceable tax liability. Internal technical or administrative glitches cannot extend the statutory limitation or validate a defective process. Consequently the demand and penalty notices for the relevant year lacked legal foundation, the return is to be treated as accepted, and any adjusted refund must be returned with interest while enforcement is restrained.
Section 144C(13) imposes an imperative one month deadline to complete assessments in conformity with Dispute Resolution Panel directions; failure to pass a final order within that period renders the assessing authority functus officio and deprives it of jurisdiction, so a draft assessment order and any notice of demand issued with it do not create an enforceable tax liability. Internal technical or administrative glitches cannot extend the statutory limitation or validate a defective process. Consequently the demand and penalty notices for the relevant year lacked legal foundation, the return is to be treated as accepted, and any adjusted refund must be returned with interest while enforcement is restrained.
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