Infrastructure facility: energy-efficient public lighting held integral to road projects, qualifying the operator as a developer and eligible for dedu...
Fourth Proviso to Section 153A: extended-period inquiry requires a reasonable, material-based satisfaction that escaped income likely exceeds the thre...
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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