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 reassessment notice issued beyond three years from the end of the relevant assessment year required prior approval from the higher authority specified under section 151(ii), not the Principal Commissioner. As the sanction was obtained from an incompetent authority, the approval was invalid and contrary to law. The Tribunal treated this defect as fatal and quashed both the reassessment notice and the consequential assessment order.
A reassessment notice issued beyond three years from the end of the relevant assessment year required prior approval from the higher authority specified under section 151(ii), not the Principal Commissioner. As the sanction was obtained from an incompetent authority, the approval was invalid and contrary to law. The Tribunal treated this defect as fatal and quashed both the reassessment notice and the consequential assessment order.
Note: It is a system-generated summary and is for quick reference only.