Reasonable Cause for Late Return: penalty under section 271(1)(c) unsustainable where disclosure, audit filing and voluntary offer showed no concealme...
Proceeds of crime and property equivalent in value: failure to explain lawful source sustains attachment; lack of required notice can vitiate confirma...
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Refund could not be denied merely because the Chartered Accountant's certificate was not in the prescribed format or did not mention the year, where the lower authority did not question the genuineness of the claim and the defect was only formal. The Tribunal held that the Board circular format was only indicative, not mandatory, and that substantial compliance was sufficient. The rejection of refund on this technical ground was therefore unsustainable. The common appellate order was set aside and the appeals were allowed with consequential benefits as per law.
Refund could not be denied merely because the Chartered Accountant's certificate was not in the prescribed format or did not mention the year, where the lower authority did not question the genuineness of the claim and the defect was only formal. The Tribunal held that the Board circular format was only indicative, not mandatory, and that substantial compliance was sufficient. The rejection of refund on this technical ground was therefore unsustainable. The common appellate order was set aside and the appeals were allowed with consequential benefits as per law.
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