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...
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The dominant issue is whether delay in filing Form No.10-IC, necessary to claim the concessional tax rate under Section 115BAA, can be condoned under Section 119(2)(b). The court held that Section 119(2)(b) empowers the CBDT (and its delegate) to condone such delay, relying on analogous High Court decisions; because non-condonation would extinguish the petitioner's substantive right to the Section 115BAA benefit and the petitioner demonstrated genuine hardship, the impugned refusal was quashed and the delay in filing Form No.10-IC was condoned. - HC
The dominant issue is whether delay in filing Form No.10-IC, necessary to claim the concessional tax rate under Section 115BAA, can be condoned under Section 119(2)(b). The court held that Section 119(2)(b) empowers the CBDT (and its delegate) to condone such delay, relying on analogous High Court decisions; because non-condonation would extinguish the petitioner's substantive right to the Section 115BAA benefit and the petitioner demonstrated genuine hardship, the impugned refusal was quashed and the delay in filing Form No.10-IC was condoned. - HC
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