Specialized Investment Fund distribution now requires dedicated certification, while transitional recognition preserves existing qualified distributor...
Overlapping GST proceedings require Central and State authorities to designate one competent authority for coordinated adjudication of the same matter...
Composite healthcare supplies retain exemption when patient care is the contract's essential character, despite payment through an implementing agency...
Receipt of immovable property requires actual possession or enjoyment; redevelopment allotments exchanged for tenancy rights fall outside deemed incom...
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A 53-day delay in filing Form 10-IC was held to be supported by bona fide reasons amounting to genuine hardship, because the taxpayer initially pursued start-up certification, then sought professional advice after refusal and arranged funds for self-assessment tax before opting for the section 115BAA regime. Applying a liberal construction of "genuine hardship" under section 119(2)(b) and the guidance in BM Malani, the Court found the delay neither deliberate nor tainted by mala fides. Refusal to condone would have denied an otherwise eligible taxpayer the section 115BAA benefit and caused substantial tax hardship. The impugned rejection was quashed and the competent authority was directed to accept the form for Assessment Year 2022-23.
A 53-day delay in filing Form 10-IC was held to be supported by bona fide reasons amounting to genuine hardship, because the taxpayer initially pursued start-up certification, then sought professional advice after refusal and arranged funds for self-assessment tax before opting for the section 115BAA regime. Applying a liberal construction of "genuine hardship" under section 119(2)(b) and the guidance in BM Malani, the Court found the delay neither deliberate nor tainted by mala fides. Refusal to condone would have denied an otherwise eligible taxpayer the section 115BAA benefit and caused substantial tax hardship. The impugned rejection was quashed and the competent authority was directed to accept the form for Assessment Year 2022-23.
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