Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
The dominant issue was whether delay in filing the return could be condoned under section 119(2)(b) on the ground of "genuine hardship." The Court held that ignorance of tax law is no excuse, and the plea of illiteracy did not establish reasonable cause, particularly since the assessee had timely filed the return for an earlier assessment year, indicating awareness of the filing process. Relying on the principle that statutory time limits must be adhered to and extension is not a vested right, the Court found no perversity in the authority's refusal to condone delay and dismissed the writ petition. - HC
The dominant issue was whether delay in filing the return could be condoned under section 119(2)(b) on the ground of "genuine hardship." The Court held that ignorance of tax law is no excuse, and the plea of illiteracy did not establish reasonable cause, particularly since the assessee had timely filed the return for an earlier assessment year, indicating awareness of the filing process. Relying on the principle that statutory time limits must be adhered to and extension is not a vested right, the Court found no perversity in the authority's refusal to condone delay and dismissed the writ petition. - HC
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