Embezzlement losses in charitable institutions remain allowable when misappropriation is established, irrecoverable, and not a specified-person benefi...
National long-distance undertaking status supports deduction where separately licensed infrastructure, resources, revenue, and expenditure establish c...
Agency reimbursement income follows contractual deposit-liability computation, while pending deposit collections do not constitute deemed-dividend loa...
Membership-consent thresholds for oppression petitions are satisfied by unchallenged voter-list consents, while unsupported forgery claims require pro...
Section 119(2)(b) permits condonation of delay in a revised return seeking refund to prevent genuine hardship, subject to the prescribed six-year limit. The competent authority must independently determine whether the refund claim is correct and genuine and whether genuine hardship exists; this power cannot be exercised routinely. A rejection cannot rest on irrelevant considerations or an unreasoned denial of hardship, and recorded reasons cannot be supplemented in court. The sufficient-cause standard for delayed appeals under the Limitation Act does not impose a stand-alone requirement to explain delay under section 119(2)(b). The refusal to condone was quashed and remitted for a fresh reasoned decision, leaving the exemption claim open.
Section 119(2)(b) permits condonation of delay in a revised return seeking refund to prevent genuine hardship, subject to the prescribed six-year limit. The competent authority must independently determine whether the refund claim is correct and genuine and whether genuine hardship exists; this power cannot be exercised routinely. A rejection cannot rest on irrelevant considerations or an unreasoned denial of hardship, and recorded reasons cannot be supplemented in court. The sufficient-cause standard for delayed appeals under the Limitation Act does not impose a stand-alone requirement to explain delay under section 119(2)(b). The refusal to condone was quashed and remitted for a fresh reasoned decision, leaving the exemption claim open.
Note: It is a system-generated summary and is for quick reference only.
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