Capital Gain Deductibility: proportionate IPO and PMS expenses held allowable against capital gains where netting and nexus to transfer are establishe...
Admissibility of Documentary Evidence: appellate authority may admit self explanatory documents on first production and uphold deletion of unexplained...
CBDT's beneficial circulars on condonation of delay for filing Form 10-IC were construed to apply to pending applications and to extend the framework prospectively, but not to revive cases where the three-year period had already expired. For AY 2020-21, the assessee was required to seek condonation within three years from the end of that assessment year, i.e. by 31.03.2024. Although liberal interpretation applies to beneficial circulars, it cannot go beyond their clear wording. An application filed on 20.01.2025 was therefore outside the circular scheme and was not entertainable under section 119(2)(b).
CBDT's beneficial circulars on condonation of delay for filing Form 10-IC were construed to apply to pending applications and to extend the framework prospectively, but not to revive cases where the three-year period had already expired. For AY 2020-21, the assessee was required to seek condonation within three years from the end of that assessment year, i.e. by 31.03.2024. Although liberal interpretation applies to beneficial circulars, it cannot go beyond their clear wording. An application filed on 20.01.2025 was therefore outside the circular scheme and was not entertainable under section 119(2)(b).
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