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...
Where the assessing officer assumed and exercised jurisdiction based on material seized during search, the non obstante effect of Section 153C prevents initiation of parallel reassessment proceedings under Sections 147/148; therefore reopenings under Sections 147/148 in such circumstances are invalid and must be quashed. A Revenue reliance on a High Court decision was rejected where intervening higher court proceedings left that judgment non final. The tribunal confirmed the appellate finding invalidating the reassessment and dismissed the Revenue appeal, leaving the substantive additions undecided on merits.
Where the assessing officer assumed and exercised jurisdiction based on material seized during search, the non obstante effect of Section 153C prevents initiation of parallel reassessment proceedings under Sections 147/148; therefore reopenings under Sections 147/148 in such circumstances are invalid and must be quashed. A Revenue reliance on a High Court decision was rejected where intervening higher court proceedings left that judgment non final. The tribunal confirmed the appellate finding invalidating the reassessment and dismissed the Revenue appeal, leaving the substantive additions undecided on merits.
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