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...
An assessment order cannot be sustained where the authority fixes a personal hearing before the assessee's last available date to file a reply to the show cause notice, because that denies a fair opportunity of hearing; the HC quashed the original order and remitted the matter for fresh hearing and decision. An appellate order rejecting an appeal is equally invalid if it fails to consider a specific condonation of delay ground and give reasons on that request, even where rejection may ultimately be justified; the HC set aside the appellate order for non-consideration of the condonation plea.
An assessment order cannot be sustained where the authority fixes a personal hearing before the assessee's last available date to file a reply to the show cause notice, because that denies a fair opportunity of hearing; the HC quashed the original order and remitted the matter for fresh hearing and decision. An appellate order rejecting an appeal is equally invalid if it fails to consider a specific condonation of delay ground and give reasons on that request, even where rejection may ultimately be justified; the HC set aside the appellate order for non-consideration of the condonation plea.
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