Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Condonation of delay requires sufficient cause, but appeals raising matters requiring examination on merits should not be excluded solely because of a technical limitation. The material explains that a pedantic refusal to consider reasons for delay may undermine merits-based adjudication, particularly where the assessee challenged denial of exemption during processing under section 143(1). Applying this approach, the delayed appeals were treated as deserving condonation, the refusal was set aside, and the matters were restored to the Commissioner (Appeals) for determination on merits.
Condonation of delay requires sufficient cause, but appeals raising matters requiring examination on merits should not be excluded solely because of a technical limitation. The material explains that a pedantic refusal to consider reasons for delay may undermine merits-based adjudication, particularly where the assessee challenged denial of exemption during processing under section 143(1). Applying this approach, the delayed appeals were treated as deserving condonation, the refusal was set aside, and the matters were restored to the Commissioner (Appeals) for determination on merits.
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