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...
An estate is assessable under section 168 on income accruing from a deceased person's assets after death, and TDS credit on dividend income belongs to the estate only if the income relates wholly to the post-death period. The ITAT found the legal position undisputed but the record insufficient to decide the relevant period, so the Assessing Officer was directed to verify that fact and grant TDS credit accordingly if the income was post-death. It also held that the Addl./Joint CIT(A) had no power to remand the matter to the Assessing Officer under section 251 in the circumstances, and disapproved that course.
An estate is assessable under section 168 on income accruing from a deceased person's assets after death, and TDS credit on dividend income belongs to the estate only if the income relates wholly to the post-death period. The ITAT found the legal position undisputed but the record insufficient to decide the relevant period, so the Assessing Officer was directed to verify that fact and grant TDS credit accordingly if the income was post-death. It also held that the Addl./Joint CIT(A) had no power to remand the matter to the Assessing Officer under section 251 in the circumstances, and disapproved that course.
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