Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
Fraud classification show-cause notices founded on inconclusive forensic audit material cannot sustain action, permitting fresh proceedings on conclus...
Appellate enhancement limits protect against new income sources, while documented credits and prior-year investments resist unexplained-income additio...
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Discretion to condone delay in filing a revised return may be exercised where revisions to tax-reporting information result in the same interest income being taxed in two assessment years. Genuine hardship must be assessed from the surrounding facts rather than a fixed formula. Double taxation, prompt pursuit of rectification remedies and absence of taxpayer inaction supported relief, while refusal would result in unjust enrichment. Permission to file the revised return was granted, subject to verification of the relevant facts and an appropriate decision in accordance with law.
Discretion to condone delay in filing a revised return may be exercised where revisions to tax-reporting information result in the same interest income being taxed in two assessment years. Genuine hardship must be assessed from the surrounding facts rather than a fixed formula. Double taxation, prompt pursuit of rectification remedies and absence of taxpayer inaction supported relief, while refusal would result in unjust enrichment. Permission to file the revised return was granted, subject to verification of the relevant facts and an appropriate decision in accordance with law.
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