https://www.taxtmi.com/caselaws?id=789577 Section 249(4)(b) bars admission of an appeal for failure to file a return only where the assessee was liable to pay advance tax; on these facts, a non-resident with no taxable income in India had no such liability, so dismissal of the quantum appeal in limine was unwarranted. The quantum addition for unexplained investment was therefore remanded to the AO for de novo adjudication after giving the assessee an opportunity to produce material. Because the penalty under section 271(1)(c) was consequential to that addition, it could not survive independently while the quantum issue remained open, and the penalty matter was also sent back for fresh consideration. en-us Wed, 08 Apr 2026 00:00:00 +0530 Fri, 10 Apr 2026 09:00:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789577 Section 249(4)(b) bars admission of an appeal for failure to file a return only where the assessee was liable to pay advance tax; on these facts, a non-resident with no taxable income in India had no such liability, so dismissal of the quantum appeal in limine was unwarranted. The quantum addition for unexplained investment was therefore remanded to the AO for de novo adjudication after giving the assessee an opportunity to produce material. Because the penalty under section 271(1)(c) was consequential to that addition, it could not survive independently while the quantum issue remained open, and the penalty matter was also sent back for fresh consideration. Case-Laws Income Tax Wed, 08 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789577