Human-probability test defeats political donation deduction where banking records mask accommodation-entry fund layering and evidence shows non-genuin...
Commercial property status protects capital-gains exemption when residential-house ownership limits are tested, while agricultural-land character gove...
Investigation deposits refunded after failed customs demands fall outside the statutory appellate pre-deposit interest regime and may attract compensa...
Resolution plan finality extinguishes unquantified operational-creditor claims and pending proceedings unless the approved plan expressly preserves th...
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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