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...
Penalty under section 271B was deleted because the assessee's accounts were audited within the prescribed time and only the uploading of the audit report was delayed due to technical glitches in the e-filing portal. The Tribunal treated this as substantial compliance with the audit requirement, held the lapse to be procedural rather than substantive, and found that the report was available before scrutiny assessment was completed without any prejudice to the Revenue. On that basis, the default was regarded as technical and venial, attracting protection under section 273B and not warranting penalty.
Penalty under section 271B was deleted because the assessee's accounts were audited within the prescribed time and only the uploading of the audit report was delayed due to technical glitches in the e-filing portal. The Tribunal treated this as substantial compliance with the audit requirement, held the lapse to be procedural rather than substantive, and found that the report was available before scrutiny assessment was completed without any prejudice to the Revenue. On that basis, the default was regarded as technical and venial, attracting protection under section 273B and not warranting penalty.
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