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...
Condonation of delay was granted where the majority of the 822 day delay fell within the pandemic period excluded by Supreme Court guidance on extension of limitation; the High Court, exercising writ jurisdiction, found no deliberate or culpable indolence and took a pragmatic, lenient view to set aside tribunal orders refusing condonation. The court emphasised that the appellate authority has competence under the appeals regime to examine material and merits when considering condonation and directed that the appeal be restored, with a fresh adjudication allowing the petitioner a personal hearing and one opportunity to adduce evidence for claimed charitable exemption.
Condonation of delay was granted where the majority of the 822 day delay fell within the pandemic period excluded by Supreme Court guidance on extension of limitation; the High Court, exercising writ jurisdiction, found no deliberate or culpable indolence and took a pragmatic, lenient view to set aside tribunal orders refusing condonation. The court emphasised that the appellate authority has competence under the appeals regime to examine material and merits when considering condonation and directed that the appeal be restored, with a fresh adjudication allowing the petitioner a personal hearing and one opportunity to adduce evidence for claimed charitable exemption.
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