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...
SC addressed the validity of reassessment notices where the decisive question was whether the matters related to Assessment Year 2015-16. It recorded the Revenue's concession that, for that year, reassessment notices would be time-barred in light of Rajeev Bansal; if a case falls in that year, the notices must be struck down without further adjudication. If the matters relate to any other assessment year, the assessees may raise all contentions available under the earlier order, and the High Courts must decide the cases accordingly. The impugned judgments were set aside and the matters remitted for fresh determination on that threshold issue first.
SC addressed the validity of reassessment notices where the decisive question was whether the matters related to Assessment Year 2015-16. It recorded the Revenue's concession that, for that year, reassessment notices would be time-barred in light of Rajeev Bansal; if a case falls in that year, the notices must be struck down without further adjudication. If the matters relate to any other assessment year, the assessees may raise all contentions available under the earlier order, and the High Courts must decide the cases accordingly. The impugned judgments were set aside and the matters remitted for fresh determination on that threshold issue first.
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