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...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
The HC quashed and set aside the impugned order dated 26 March 2025 passed by the respondent under s.119(2)(b) and condoned a delay of 133 days in electronically filing Form No.10B for AY 2019-20. The court found the lapse was inadvertent, not deliberate or mala fide, attributable to the petitioner's auditor, and the petitioner-a charitable trust running educational institutions-had otherwise complied with statutory requirements and obtained the audit report timely. Refusal to condone would have caused grave injustice and financial hardship. Consequently, the denial of exemption under s.11 premised solely on the technical non-filing was effectively set aside and relief granted.
The HC quashed and set aside the impugned order dated 26 March 2025 passed by the respondent under s.119(2)(b) and condoned a delay of 133 days in electronically filing Form No.10B for AY 2019-20. The court found the lapse was inadvertent, not deliberate or mala fide, attributable to the petitioner's auditor, and the petitioner-a charitable trust running educational institutions-had otherwise complied with statutory requirements and obtained the audit report timely. Refusal to condone would have caused grave injustice and financial hardship. Consequently, the denial of exemption under s.11 premised solely on the technical non-filing was effectively set aside and relief granted.
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