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...
A taxpayer showing prima facie prior payment of the same tax amount was entitled to place proof before the proper officer through a rectification application before any recovery action was taken. Where the revenue could not dispute that the receipt corresponded to the amount later treated as short-paid, the court directed verification in accordance with law to avoid double recovery of tax already paid. The petitioner was permitted to file the rectification application within the time granted, and the proper officer was required to consider it within a reasonable period.
A taxpayer showing prima facie prior payment of the same tax amount was entitled to place proof before the proper officer through a rectification application before any recovery action was taken. Where the revenue could not dispute that the receipt corresponded to the amount later treated as short-paid, the court directed verification in accordance with law to avoid double recovery of tax already paid. The petitioner was permitted to file the rectification application within the time granted, and the proper officer was required to consider it within a reasonable period.
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