International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
Transaction value between related persons requires market-equivalent pricing; importer must prove declared value mirrors ordinary international trade ...
Classification of exported insecticides under export tariff affirmed; reclassification and related penalties set aside and MEIS scrip jurisdiction rec...
A High Court held that a beneficial CBDT circular issued under section 119(2)(b) for condonation of delay in filing prescribed forms must be applied to genuine and bona fide cases, even where the assessment year is not expressly named. The court found that the relevant circular was the one dated 18.11.2024, which addressed condonation of delay, and that omission of AY 2023-24 was not decisive because the circular was meant to remedy genuine hardship. Rejecting a narrow year-specific reading as anomalous and unjust, the court set aside the refusal order and remitted the matter for fresh consideration in accordance with law.
A High Court held that a beneficial CBDT circular issued under section 119(2)(b) for condonation of delay in filing prescribed forms must be applied to genuine and bona fide cases, even where the assessment year is not expressly named. The court found that the relevant circular was the one dated 18.11.2024, which addressed condonation of delay, and that omission of AY 2023-24 was not decisive because the circular was meant to remedy genuine hardship. Rejecting a narrow year-specific reading as anomalous and unjust, the court set aside the refusal order and remitted the matter for fresh consideration in accordance with law.
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