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...
In valuation of house construction for unexplained investment, local State PWD rates were preferred over CPWD rates because they better reflect market conditions. The Tribunal also allowed a 15% deduction for self-supervision where no technical person was employed, after noting that the appellate authority had already corrected valuation defects and accepted the relevant measurements. After applying the rate adjustment and self-supervision relief, the difference with the books fell within the 5% tolerance band. No addition for cost of construction was therefore warranted, and the disputed valuation addition was deleted.
In valuation of house construction for unexplained investment, local State PWD rates were preferred over CPWD rates because they better reflect market conditions. The Tribunal also allowed a 15% deduction for self-supervision where no technical person was employed, after noting that the appellate authority had already corrected valuation defects and accepted the relevant measurements. After applying the rate adjustment and self-supervision relief, the difference with the books fell within the 5% tolerance band. No addition for cost of construction was therefore warranted, and the disputed valuation addition was deleted.
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