Condonation of Delay: Tribunal directed condonation where rectification proceedings were pursued, ordering merits adjudication after opportunity to be...
Restriction of Input Tax Credit under Rule 86A applies only to fraudulently or ineligible availed credit; mere wrongful recipient availment is insuffi...
Assessment under section 147 read with section 144B was not vitiated merely because notice under section 143(2) was issued by the Jurisdictional Assessing Officer and the reassessment was completed through the faceless regime; the Tribunal held that concurrent jurisdiction survives and rejected the legal challenge. On merits, however, additions based on treating full sale consideration as short-term capital gain, ad hoc estimation of contract and professional receipts, and addition of rent receipts as business income were set aside because they were made without proper verification of cost, books, reconciliation, or supporting documents. The matter was remanded for fresh examination, with the assessee's non-compliance noted as a material factor.
Assessment under section 147 read with section 144B was not vitiated merely because notice under section 143(2) was issued by the Jurisdictional Assessing Officer and the reassessment was completed through the faceless regime; the Tribunal held that concurrent jurisdiction survives and rejected the legal challenge. On merits, however, additions based on treating full sale consideration as short-term capital gain, ad hoc estimation of contract and professional receipts, and addition of rent receipts as business income were set aside because they were made without proper verification of cost, books, reconciliation, or supporting documents. The matter was remanded for fresh examination, with the assessee's non-compliance noted as a material factor.
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