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...
Jurisdiction for notice under section 148 was tested on the material available when proceedings began, not on the income ultimately assessed. The Tribunal held that section 149(1)(b) permitted notice beyond three years where the Assessing Officer possessed books, documents or evidence indicating income represented in the form of an asset and likely to meet the statutory threshold. Cash withdrawals exceeding Rs. 1.50 crores, together with non-filing of a return, constituted tangible material for a prima facie view that the threshold was satisfied. The assessee's time-bar objection failed, and the reassessment notice was upheld as valid.
Jurisdiction for notice under section 148 was tested on the material available when proceedings began, not on the income ultimately assessed. The Tribunal held that section 149(1)(b) permitted notice beyond three years where the Assessing Officer possessed books, documents or evidence indicating income represented in the form of an asset and likely to meet the statutory threshold. Cash withdrawals exceeding Rs. 1.50 crores, together with non-filing of a return, constituted tangible material for a prima facie view that the threshold was satisfied. The assessee's time-bar objection failed, and the reassessment notice was upheld as valid.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
