Retrospective application of beneficial circulars upheld, binding officers and granting post adjudication relief where adjudication occurred after cir...
Admissibility of Investigation Statements requires witness examination before the adjudicating authority; otherwise statements cannot sustain a penalt...
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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