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 jurisdictional challenge to reassessment under section 147, raised for the first time in cross-objection on the footing that section 153C should have applied, was not entertained because it required fresh factual inquiry beyond the existing appellate record and no such challenge had been raised before the first appellate authority. The tribunal also upheld best judgment estimation of commission income from accommodation entries, holding that the appellate authority could not replace the Assessing Officer's estimate of 2% with 0.5% without identifying any evidentiary or legal infirmity in the original estimate. The assessee's cross-objections were dismissed and the additions were restored.
A jurisdictional challenge to reassessment under section 147, raised for the first time in cross-objection on the footing that section 153C should have applied, was not entertained because it required fresh factual inquiry beyond the existing appellate record and no such challenge had been raised before the first appellate authority. The tribunal also upheld best judgment estimation of commission income from accommodation entries, holding that the appellate authority could not replace the Assessing Officer's estimate of 2% with 0.5% without identifying any evidentiary or legal infirmity in the original estimate. The assessee's cross-objections were dismissed and the additions were restored.
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