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...
Reassessment was quashed because the recorded reasons suffered from fundamental defects: no proper approval in the prescribed form, absence of signature on sanction, and material factual errors in the basis for reopening. The assessing officer's later attempt to substitute fresh reasons was not permitted under section 147, and the alternative reasons still rested on suspicion, third-party information about the assessee's husband, and no independent tangible material showing escapement in the assessee's own case. The Tribunal held this amounted only to a reason to suspect, not a valid reason to believe. Cross-objections were also rejected as time-barred, since they were filed 27 days late without any condonation request.
Reassessment was quashed because the recorded reasons suffered from fundamental defects: no proper approval in the prescribed form, absence of signature on sanction, and material factual errors in the basis for reopening. The assessing officer's later attempt to substitute fresh reasons was not permitted under section 147, and the alternative reasons still rested on suspicion, third-party information about the assessee's husband, and no independent tangible material showing escapement in the assessee's own case. The Tribunal held this amounted only to a reason to suspect, not a valid reason to believe. Cross-objections were also rejected as time-barred, since they were filed 27 days late without any condonation request.
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