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...
HC held that reassessment based on an undated third-party complaint and other unverified material could not be sustained where there was no direct nexus with the assessee. The complaint was not authenticated, its author was not examined, and no further investigation linked the petitioner to any alleged cash transaction. The statements later recorded and the image of the cash receipt also failed to show any transaction by or with the petitioner. Reopening founded on conjectures and surmises was therefore unsustainable, and the reassessment notices and the order under section 148A(3) were quashed.
HC held that reassessment based on an undated third-party complaint and other unverified material could not be sustained where there was no direct nexus with the assessee. The complaint was not authenticated, its author was not examined, and no further investigation linked the petitioner to any alleged cash transaction. The statements later recorded and the image of the cash receipt also failed to show any transaction by or with the petitioner. Reopening founded on conjectures and surmises was therefore unsustainable, and the reassessment notices and the order under section 148A(3) were quashed.
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