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External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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The HC allowed the petition and set aside the impugned order rejecting condonation of delay in filing the Return of Income for A.Y. 2024-25. The court held that reliance on professional advice does not preclude genuine hardship or errors causing delay. It clarified that proof of deduction claim under section 80IBA is not required at the condonation stage but during assessment, which depends on acceptance of the return. The court emphasized a liberal interpretation of "genuine hardship," noting refusal to condone delay could unjustly bar a meritorious claim. Condoning the delay enables adjudication on merits rather than dismissal on technical grounds. Consequently, the delay in filing the return was condoned to prevent substantial prejudice to the petitioner's rights.
The HC allowed the petition and set aside the impugned order rejecting condonation of delay in filing the Return of Income for A.Y. 2024-25. The court held that reliance on professional advice does not preclude genuine hardship or errors causing delay. It clarified that proof of deduction claim under section 80IBA is not required at the condonation stage but during assessment, which depends on acceptance of the return. The court emphasized a liberal interpretation of "genuine hardship," noting refusal to condone delay could unjustly bar a meritorious claim. Condoning the delay enables adjudication on merits rather than dismissal on technical grounds. Consequently, the delay in filing the return was condoned to prevent substantial prejudice to the petitioner's rights.
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