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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...
HC held that a rectification order under Section 154(7) cannot be passed after four years from the end of the financial year in which the original order was made. As the original order was dated February 25, 2015, the limitation expired on March 31, 2019, but the rectification order was issued on March 25, 2022; it was therefore time-barred and a jurisdictional error. The Court also noted that the Department had not shown service of prior notice under Section 154(3), and accepted the objection that the order lacked a Document Identification Number. The writ petition was allowed and the rectification order, together with consequential recovery proceedings, was set aside.
HC held that a rectification order under Section 154(7) cannot be passed after four years from the end of the financial year in which the original order was made. As the original order was dated February 25, 2015, the limitation expired on March 31, 2019, but the rectification order was issued on March 25, 2022; it was therefore time-barred and a jurisdictional error. The Court also noted that the Department had not shown service of prior notice under Section 154(3), and accepted the objection that the order lacked a Document Identification Number. The writ petition was allowed and the rectification order, together with consequential recovery proceedings, was set aside.
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