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...
Section 148A(b) requires at least seven days to respond; a notice granting only five days was held contrary to statute, and the assessee's later extension request did not cure the defect. The resulting order under section 148A(d) and reassessment were therefore unsustainable. The notice under section 148 was also time-barred, as the limitation for A.Y. 2015-16 expired on 31/03/2022 but the notice was issued on 04/04/2022. On merits, the addition for unexplained investment could not be made wholly in the assessee's hands because the sale deed showed joint ownership of the property with his wife.
Section 148A(b) requires at least seven days to respond; a notice granting only five days was held contrary to statute, and the assessee's later extension request did not cure the defect. The resulting order under section 148A(d) and reassessment were therefore unsustainable. The notice under section 148 was also time-barred, as the limitation for A.Y. 2015-16 expired on 31/03/2022 but the notice was issued on 04/04/2022. On merits, the addition for unexplained investment could not be made wholly in the assessee's hands because the sale deed showed joint ownership of the property with his wife.
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