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...
Failure to afford a personal hearing and reliance on portal-only notice rendered confirmation of show-cause proposals procedurally invalid; the assessment order was set aside and matter remanded. The article explains that while uploading notices on the IT portal can constitute service, the assessing officer must apply mind where the taxpayer does not respond and must explore other prescribed modes of service (for example, registered post with acknowledgement) to secure effective communication. Remedial directions require conditional payment, portal access to file replies, issuance of a clear 14-day notice by registered post fixing a personal hearing date, and fresh adjudication after hearing.
Failure to afford a personal hearing and reliance on portal-only notice rendered confirmation of show-cause proposals procedurally invalid; the assessment order was set aside and matter remanded. The article explains that while uploading notices on the IT portal can constitute service, the assessing officer must apply mind where the taxpayer does not respond and must explore other prescribed modes of service (for example, registered post with acknowledgement) to secure effective communication. Remedial directions require conditional payment, portal access to file replies, issuance of a clear 14-day notice by registered post fixing a personal hearing date, and fresh adjudication after hearing.
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