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...
ITAT held that an ad hoc 20% disallowance of truck rent expenses could not stand where the assessee had filed supporting details, sample invoices and vehicle registration papers, but the AO had not made proper verification, enquiries or rejected the books of account. As similar expenditure in the assessee's own earlier year had been restricted to 2% by a speaking order, and no distinguishing facts were shown, the disallowance was confined to 2%. The separate addition relating to unpaid motor truck rent was not upheld on the existing record and was remanded to the AO for verification after giving the assessee one further opportunity of hearing.
ITAT held that an ad hoc 20% disallowance of truck rent expenses could not stand where the assessee had filed supporting details, sample invoices and vehicle registration papers, but the AO had not made proper verification, enquiries or rejected the books of account. As similar expenditure in the assessee's own earlier year had been restricted to 2% by a speaking order, and no distinguishing facts were shown, the disallowance was confined to 2%. The separate addition relating to unpaid motor truck rent was not upheld on the existing record and was remanded to the AO for verification after giving the assessee one further opportunity of hearing.
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