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...
The determinative issue was whether the Assessing Officer had made the enquiry required before the Principal Commissioner invoked revision under section 263. The High Court treated that enquiry question as a pure question of fact, and held that the Tribunal's finding on it could not be converted into a substantial question of law under section 260A. As the Revenue's challenge depended on whether assessment proceedings were conducted with or without enquiry, the appeal was not entertainable on the basis urged and was rejected.
The determinative issue was whether the Assessing Officer had made the enquiry required before the Principal Commissioner invoked revision under section 263. The High Court treated that enquiry question as a pure question of fact, and held that the Tribunal's finding on it could not be converted into a substantial question of law under section 260A. As the Revenue's challenge depended on whether assessment proceedings were conducted with or without enquiry, the appeal was not entertainable on the basis urged and was rejected.
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