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...
CBDT Instruction No. 01/2011 placed jurisdiction over a corporate assessee in Kolkata with income above the prescribed limit in the AC/DC, so a reassessment notice issued by the Income Tax Officer lacked authority and the reopening was void ab initio. Separately, the Tribunal held that the NFAC had no jurisdiction to pass the reassessment order before the section 151A notification bringing the scheme into force, making that order equally void ab initio. The reassessment proceedings were therefore unsustainable on jurisdictional grounds and the assessee's appeal was allowed.
CBDT Instruction No. 01/2011 placed jurisdiction over a corporate assessee in Kolkata with income above the prescribed limit in the AC/DC, so a reassessment notice issued by the Income Tax Officer lacked authority and the reopening was void ab initio. Separately, the Tribunal held that the NFAC had no jurisdiction to pass the reassessment order before the section 151A notification bringing the scheme into force, making that order equally void ab initio. The reassessment proceedings were therefore unsustainable on jurisdictional grounds and the assessee's appeal was allowed.
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