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...
Cash received as sale consideration on registration of immovable property deeds was held outside the mischief of section 269SS, because the provision was applied to advances in property transactions and not to completed transfer consideration duly reflected in registered documents. On that footing, penalty under section 271D could not be sustained. The Tribunal also held that valid initiation of penalty required recorded satisfaction by the Assessing Officer in the assessment or other proceedings, and no such satisfaction was shown on the record. The penalty was therefore quashed and deleted.
Cash received as sale consideration on registration of immovable property deeds was held outside the mischief of section 269SS, because the provision was applied to advances in property transactions and not to completed transfer consideration duly reflected in registered documents. On that footing, penalty under section 271D could not be sustained. The Tribunal also held that valid initiation of penalty required recorded satisfaction by the Assessing Officer in the assessment or other proceedings, and no such satisfaction was shown on the record. The penalty was therefore quashed and deleted.
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