Writ relief against show cause notices is available where jurisdiction is absent and concluded advance rulings cannot be reopened without fresh fraud ...
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On an application for condonation of delay in filing Form 10B under section 119(2)(b), the HC held that the authority had to confine itself to the explanation for delay and could not reject relief on an unrelated ground. The petitioner had explained that the audit report was uploaded within time and that the delay arose only in portal acceptance or verification. By refusing condonation because the registration certificate under section 12AA was not produced, the authority exceeded the limited scope of inquiry. The order was quashed and the matter remanded for fresh consideration of the delay explanation alone.
On an application for condonation of delay in filing Form 10B under section 119(2)(b), the HC held that the authority had to confine itself to the explanation for delay and could not reject relief on an unrelated ground. The petitioner had explained that the audit report was uploaded within time and that the delay arose only in portal acceptance or verification. By refusing condonation because the registration certificate under section 12AA was not produced, the authority exceeded the limited scope of inquiry. The order was quashed and the matter remanded for fresh consideration of the delay explanation alone.
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