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...
Reassessment under Section 148 requires prima facie material showing a live link between the seized material and alleged income escaping assessment. The High Court held that vague, non-specific loose papers referring only to survey numbers, a rate and a third person's name, without the assessee's name or any nexus to her, could not justify reopening. The expressions "relates to" and "pertains to" in Explanation 2 to Section 148 cannot be applied in isolation; the Revenue must assess the material against surrounding circumstances and record prima facie relevancy. As the information lacked that connection, the notice and consequential reopening were quashed.
Reassessment under Section 148 requires prima facie material showing a live link between the seized material and alleged income escaping assessment. The High Court held that vague, non-specific loose papers referring only to survey numbers, a rate and a third person's name, without the assessee's name or any nexus to her, could not justify reopening. The expressions "relates to" and "pertains to" in Explanation 2 to Section 148 cannot be applied in isolation; the Revenue must assess the material against surrounding circumstances and record prima facie relevancy. As the information lacked that connection, the notice and consequential reopening were quashed.
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