Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Decision addresses entitlement to deduction under Chapter VI-A (80P) and holds that the statutory scheme requires the claim for such deduction to be made in the return of income and that the return must be filed within the due date under the relevant return-filing provision. The court rejects the contention that absence of any return exempts an assessee from the bar in sub-section (5) and, applying a conjoint reading with the companion provision, concludes that failure to file a timely return or to claim the deduction in the return precludes allowance of the deduction; the tribunals application of that approach was upheld.
Decision addresses entitlement to deduction under Chapter VI-A (80P) and holds that the statutory scheme requires the claim for such deduction to be made in the return of income and that the return must be filed within the due date under the relevant return-filing provision. The court rejects the contention that absence of any return exempts an assessee from the bar in sub-section (5) and, applying a conjoint reading with the companion provision, concludes that failure to file a timely return or to claim the deduction in the return precludes allowance of the deduction; the tribunals application of that approach was upheld.
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