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...
The Tribunal examined multiple search-related assessment issues, including section 68 cash credits, section 69C unexplained expenditure, bogus purchases, stock discrepancy, employees' contribution disallowance, and section 153A jurisdiction. It held that primary evidence such as confirmations, PAN, returns and bank statements was sufficient for section 68, and the Revenue had to conduct independent verification; the source of source was not required on these facts. It also sustained only the profit element in disputed purchases, deleted a stock-difference addition after reconciliation and valuation defects, remanded one seized-noting issue for fresh verification, upheld disallowance of delayed employees' contribution, and rejected the challenge to assessments based on seized material.
The Tribunal examined multiple search-related assessment issues, including section 68 cash credits, section 69C unexplained expenditure, bogus purchases, stock discrepancy, employees' contribution disallowance, and section 153A jurisdiction. It held that primary evidence such as confirmations, PAN, returns and bank statements was sufficient for section 68, and the Revenue had to conduct independent verification; the source of source was not required on these facts. It also sustained only the profit element in disputed purchases, deleted a stock-difference addition after reconciliation and valuation defects, remanded one seized-noting issue for fresh verification, upheld disallowance of delayed employees' contribution, and rejected the challenge to assessments based on seized material.
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