Religious purpose exclusion versus charitable purpose: non overriding religious objects do not attract Explanation 3, registration directed under sect...
Search-assessment proviso jurisdiction, time-barred valuation reports, and denial of cross-examination vitiate valuation-based and confession-based ad...
Condonation of delay and limitation for preferring statutory appeals was determinative: the appellate forum found repeated adjournments and that the appeal was filed after the condonable period, so the Commissioner (Appeal) correctly held the appeal time-barred and dismissed it. The tribunal applied the proviso limiting discretionary exemptions in appeals and relied on the Supreme Court precedent that the Commissioner cannot condone delay beyond the short statutory condonation window, producing dismissal on limitation grounds. Forum shopping and invocation of writ jurisdiction were noted but did not alter the limitation outcome.
Condonation of delay and limitation for preferring statutory appeals was determinative: the appellate forum found repeated adjournments and that the appeal was filed after the condonable period, so the Commissioner (Appeal) correctly held the appeal time-barred and dismissed it. The tribunal applied the proviso limiting discretionary exemptions in appeals and relied on the Supreme Court precedent that the Commissioner cannot condone delay beyond the short statutory condonation window, producing dismissal on limitation grounds. Forum shopping and invocation of writ jurisdiction were noted but did not alter the limitation outcome.
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