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HC held that CBDT condonation circulars for delayed filing by co-operative societies must be read liberally to relieve genuine hardship, not narrowly through hyper-technical demands for day-to-day explanations. Where the societies were otherwise eligible for deduction and the delay stemmed from audit-related compliance difficulties, the lapse was a procedural default against a substantive entitlement. In the absence of any allegation of tax evasion, the rejection orders were unsustainable. The condonation applications were treated as allowed, and the assessment and appellate authorities were directed to proceed on the footing that the delay in filing the returns stood condoned.
HC held that CBDT condonation circulars for delayed filing by co-operative societies must be read liberally to relieve genuine hardship, not narrowly through hyper-technical demands for day-to-day explanations. Where the societies were otherwise eligible for deduction and the delay stemmed from audit-related compliance difficulties, the lapse was a procedural default against a substantive entitlement. In the absence of any allegation of tax evasion, the rejection orders were unsustainable. The condonation applications were treated as allowed, and the assessment and appellate authorities were directed to proceed on the footing that the delay in filing the returns stood condoned.
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