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...
ITAT held that omission to mention a Document Identification Number in the initiating notice did not invalidate the proceeding, because the retrospective validation under section 292BA cures a mere mistake, defect or omission where the order is otherwise referenced by DIN; the assessee's objection also had not been raised before the first appellate authority. On the penalty for cash acceptance, the Tribunal held that section 269SS applies only to receipt of a loan or deposit, not to repayment of earlier advances, but the factual nature of the receipts was not established on record. The matter was therefore remanded for fresh adjudication after giving the assessee one further opportunity to produce evidence.
ITAT held that omission to mention a Document Identification Number in the initiating notice did not invalidate the proceeding, because the retrospective validation under section 292BA cures a mere mistake, defect or omission where the order is otherwise referenced by DIN; the assessee's objection also had not been raised before the first appellate authority. On the penalty for cash acceptance, the Tribunal held that section 269SS applies only to receipt of a loan or deposit, not to repayment of earlier advances, but the factual nature of the receipts was not established on record. The matter was therefore remanded for fresh adjudication after giving the assessee one further opportunity to produce evidence.
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