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...
A revision under section 263 was sustained where the Assessing Officer had not made the enquiry and verification the scrutiny assessment required. The Tribunal noted that only generalized notices had been issued, with no real examination, follow-up enquiry or application of mind on the selected scrutiny issues, including expense claims, related-party payments and tax deduction defaults. It applied the principle that merely calling for details and filing them on record is not enough to constitute enquiry, and that Explanation 2(a) to section 263 applies when no proper view is formed after due examination. The assessee's contention that disclosure of details barred revision was rejected.
A revision under section 263 was sustained where the Assessing Officer had not made the enquiry and verification the scrutiny assessment required. The Tribunal noted that only generalized notices had been issued, with no real examination, follow-up enquiry or application of mind on the selected scrutiny issues, including expense claims, related-party payments and tax deduction defaults. It applied the principle that merely calling for details and filing them on record is not enough to constitute enquiry, and that Explanation 2(a) to section 263 applies when no proper view is formed after due examination. The assessee's contention that disclosure of details barred revision was rejected.
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