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...
Reassessment notices issued under the new regime were held time-barred because, for notices originally issued between 01/04/2021 and 30/06/2021, only the surviving time available up to 30/06/2021 could be used after excluding the stayed period and the two weeks allowed for response. Applying the Supreme Court rulings in Rajeev Bansal and Ashish Agarwal, the Tribunal held that the fresh notice had to be issued within the remaining limitation under section 149. In this case, the notice issued on 25/07/2022 exceeded that limit, so the reassessment proceedings and assessment orders were quashed, with other grounds left open.
Reassessment notices issued under the new regime were held time-barred because, for notices originally issued between 01/04/2021 and 30/06/2021, only the surviving time available up to 30/06/2021 could be used after excluding the stayed period and the two weeks allowed for response. Applying the Supreme Court rulings in Rajeev Bansal and Ashish Agarwal, the Tribunal held that the fresh notice had to be issued within the remaining limitation under section 149. In this case, the notice issued on 25/07/2022 exceeded that limit, so the reassessment proceedings and assessment orders were quashed, with other grounds left open.
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