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 HC sustained rejection of a revision application filed with a delay of 1,460 days because the explanation of partner disputes was vague and did not establish sufficient cause. It noted that the firm continued to comply with statutory obligations, including audits and return filing, during the alleged period of impediment, showing no inability to file on time. As the Commissioner's view on unexplained delay was a plausible one, no interference was warranted in writ jurisdiction. The Court also held that, once delay was the ground of rejection, the authority should not have commented on merits; those observations were directed to be ignored and not treated as precedent.
The HC sustained rejection of a revision application filed with a delay of 1,460 days because the explanation of partner disputes was vague and did not establish sufficient cause. It noted that the firm continued to comply with statutory obligations, including audits and return filing, during the alleged period of impediment, showing no inability to file on time. As the Commissioner's view on unexplained delay was a plausible one, no interference was warranted in writ jurisdiction. The Court also held that, once delay was the ground of rejection, the authority should not have commented on merits; those observations were directed to be ignored and not treated as precedent.
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