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...
DCF share valuation could not be discarded and replaced with another fair market value without first identifying a specific defect or non-compliance in the assessee's prescribed valuation report, so the addition for excess share premium under section 56(2)(vii)(b) was deleted. Protective assessment was confined to cases of doubt about the correct person chargeable to tax; where both additions were made in the same assessee's hands in the same year under different heads, that basis did not apply, so the section 68 protective addition was also deleted. The appeal was allowed.
DCF share valuation could not be discarded and replaced with another fair market value without first identifying a specific defect or non-compliance in the assessee's prescribed valuation report, so the addition for excess share premium under section 56(2)(vii)(b) was deleted. Protective assessment was confined to cases of doubt about the correct person chargeable to tax; where both additions were made in the same assessee's hands in the same year under different heads, that basis did not apply, so the section 68 protective addition was also deleted. The appeal was allowed.
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