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 validity depended on two jurisdictional defects: the sanction under section 151 was held invalid because the escapement figure shifted from Rs. 1,11,37,000 to Rs. 66,13,961 and then to Rs. 27,00,000, showing non-application of mind at the sanction stage. The Tribunal also held that reopening beyond three years was unsustainable because the surviving alleged escapement was below the Rs. 50 lakh threshold required for extended limitation under section 149(1). On these grounds, the reassessment was held untenable and the remaining issues were left open.
Reassessment validity depended on two jurisdictional defects: the sanction under section 151 was held invalid because the escapement figure shifted from Rs. 1,11,37,000 to Rs. 66,13,961 and then to Rs. 27,00,000, showing non-application of mind at the sanction stage. The Tribunal also held that reopening beyond three years was unsustainable because the surviving alleged escapement was below the Rs. 50 lakh threshold required for extended limitation under section 149(1). On these grounds, the reassessment was held untenable and the remaining issues were left open.
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