Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Belated filing of the audit report in Form No.10B raised the legal issue of condonation of delay under Section 119(2)(b); the HC applied the principle that bona fide reasons and pandemic-related regulatory extensions justify condonation and considered genuine hardship to the assessee from denial of exemption under Section 11. The court found COVID-19 disruptions and timely extensions by authorities established bona fides, held that failure to condone would cause genuine hardship, quashed the rejection of the condonation application and directed reprocessing of the return for assessment year 2020-2021.
Belated filing of the audit report in Form No.10B raised the legal issue of condonation of delay under Section 119(2)(b); the HC applied the principle that bona fide reasons and pandemic-related regulatory extensions justify condonation and considered genuine hardship to the assessee from denial of exemption under Section 11. The court found COVID-19 disruptions and timely extensions by authorities established bona fides, held that failure to condone would cause genuine hardship, quashed the rejection of the condonation application and directed reprocessing of the return for assessment year 2020-2021.
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