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 107(4) gives the Appellate Authority discretion to admit an appeal within the additional one-month condonable period if sufficient cause prevented timely filing. Where an appeal is presented within that period, the authority must examine the explanation for delay on its merits, including uncertainty created by overlapping statutory changes and portal-related constraints. Rejection as time-barred without properly considering that explanation is unsustainable. The appeal was therefore restored for fresh consideration on merits.
Section 107(4) gives the Appellate Authority discretion to admit an appeal within the additional one-month condonable period if sufficient cause prevented timely filing. Where an appeal is presented within that period, the authority must examine the explanation for delay on its merits, including uncertainty created by overlapping statutory changes and portal-related constraints. Rejection as time-barred without properly considering that explanation is unsustainable. The appeal was therefore restored for fresh consideration on merits.
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