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...
Concessional electricity charges under Clause 16(a) of the 2019 Industrial Policy were held to apply only to new industrial enterprises, while existing enterprises undertaking substantial expansion fell under Clause 16(b) and could claim only the rebate linked to incremental consumption. The 29.04.2022 amendment substituting "eligible" with "new" in Clause 16(a) and aligning Clause 16(b) with substantial expansion was treated as clarificatory and retrospective, except for the newly introduced three-year duration under Clause 16(b), which operated prospectively. The respondent therefore had no entitlement to Clause 16(a) concession, and promissory estoppel could not create a benefit beyond the Policy's true scope.
Concessional electricity charges under Clause 16(a) of the 2019 Industrial Policy were held to apply only to new industrial enterprises, while existing enterprises undertaking substantial expansion fell under Clause 16(b) and could claim only the rebate linked to incremental consumption. The 29.04.2022 amendment substituting "eligible" with "new" in Clause 16(a) and aligning Clause 16(b) with substantial expansion was treated as clarificatory and retrospective, except for the newly introduced three-year duration under Clause 16(b), which operated prospectively. The respondent therefore had no entitlement to Clause 16(a) concession, and promissory estoppel could not create a benefit beyond the Policy's true scope.
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