Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
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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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