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 composite show cause notice under Section 74 clubbing multiple financial years was held impermissible because the statutory scheme operates tax period-wise and year-wise, with separate return obligations and limitation consequences for each period. The Court followed its own binding precedent and held that authorities within its jurisdiction were bound by that view until stayed or overruled; dismissal in limine of a contrary challenge did not create merger on merits. The composite notice and consequential order were quashed, with liberty to issue a fresh notice strictly in accordance with law.
A composite show cause notice under Section 74 clubbing multiple financial years was held impermissible because the statutory scheme operates tax period-wise and year-wise, with separate return obligations and limitation consequences for each period. The Court followed its own binding precedent and held that authorities within its jurisdiction were bound by that view until stayed or overruled; dismissal in limine of a contrary challenge did not create merger on merits. The composite notice and consequential order were quashed, with liberty to issue a fresh notice strictly in accordance with law.
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