Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
CBDT Circular No. 13/2023 specifically governs condonation applications by co-operative societies that filed delayed returns while claiming deduction under section 80P for covered assessment years, displacing the general framework in Circular No. 09/2015 for refunds and loss carry-forwards. Reliance solely on the general circular without considering the specific circular reflects non-application of mind. COVID-19 restrictions and delayed statutory audit reports routed through the State Audit Department may constitute genuine hardship under Circular No. 13/2023. Condonation relief under section 119(2)(b) should be applied liberally rather than defeated on a hyper-technical basis, enabling consideration of a qualifying section 80P claim on merits.
CBDT Circular No. 13/2023 specifically governs condonation applications by co-operative societies that filed delayed returns while claiming deduction under section 80P for covered assessment years, displacing the general framework in Circular No. 09/2015 for refunds and loss carry-forwards. Reliance solely on the general circular without considering the specific circular reflects non-application of mind. COVID-19 restrictions and delayed statutory audit reports routed through the State Audit Department may constitute genuine hardship under Circular No. 13/2023. Condonation relief under section 119(2)(b) should be applied liberally rather than defeated on a hyper-technical basis, enabling consideration of a qualifying section 80P claim on merits.
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TaxTMI 
TaxTMI 
