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...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
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The HC condoned the delay of 799 days by the petitioner in filing Form 9A u/s 119(2)(b) of the Income Tax Act. Despite the delay being bona fide, the Assessing Officer rejected the belated filing on hyper-technical grounds without considering the petitioner's justification letters. The HC held that dissuading belated filing can be counterproductive and where sufficient cause for delay is explained, it ought to be condoned to uphold the object and purpose of tax laws. Consequently, the petitioner's delay supported by sufficient cause was condoned.
The HC condoned the delay of 799 days by the petitioner in filing Form 9A u/s 119(2)(b) of the Income Tax Act. Despite the delay being bona fide, the Assessing Officer rejected the belated filing on hyper-technical grounds without considering the petitioner's justification letters. The HC held that dissuading belated filing can be counterproductive and where sufficient cause for delay is explained, it ought to be condoned to uphold the object and purpose of tax laws. Consequently, the petitioner's delay supported by sufficient cause was condoned.
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