Co-operative society's mandatory reserve and share capital fixed deposits with banks-interest treated as business income under 80P(2)(a)(iii) deductio...
Income tax reassessment reopening after four years on investigation tip, without s.147 proviso disclosure failure, struck down as borrowed satisfactio...
An application under Section 119(2)(b) challenged refusal to permit filing a revised return beyond five years; the High Court found the taxpayer had pursued rectification within the five year window and had reasonably relied on rectification as the remedy. The court held the authority could not ignore the circular's temporal condition, treated the misdeclaration as a bona fide error without deciding revised return merits, set aside the impugned order and remitted the matter for fresh consideration of the revised return for the relevant assessment year in accordance with law.
An application under Section 119(2)(b) challenged refusal to permit filing a revised return beyond five years; the High Court found the taxpayer had pursued rectification within the five year window and had reasonably relied on rectification as the remedy. The court held the authority could not ignore the circular's temporal condition, treated the misdeclaration as a bona fide error without deciding revised return merits, set aside the impugned order and remitted the matter for fresh consideration of the revised return for the relevant assessment year in accordance with law.
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