Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
The HC quashed the order under s.119(2)(b) and condoned the delay in filing income tax return for AY 2020-21, allowing the petitioner to claim refund belatedly. The court recognized genuine hardship faced by the non-resident petitioner who was prevented from filing returns due to COVID-19 travel restrictions and late deposit of TDS by the property purchaser (M/s. Ashutosh Builders) on 11.06.2022. The petitioner had already furnished income computation with long-term capital gain details in response to the tax authority's notice. The HC determined these circumstances constituted sufficient grounds for condonation of delay under the Income Tax Act provisions.
The HC quashed the order under s.119(2)(b) and condoned the delay in filing income tax return for AY 2020-21, allowing the petitioner to claim refund belatedly. The court recognized genuine hardship faced by the non-resident petitioner who was prevented from filing returns due to COVID-19 travel restrictions and late deposit of TDS by the property purchaser (M/s. Ashutosh Builders) on 11.06.2022. The petitioner had already furnished income computation with long-term capital gain details in response to the tax authority's notice. The HC determined these circumstances constituted sufficient grounds for condonation of delay under the Income Tax Act provisions.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
