Retrospective application of beneficial circulars upheld, binding officers and granting post adjudication relief where adjudication occurred after cir...
Admissibility of Investigation Statements requires witness examination before the adjudicating authority; otherwise statements cannot sustain a penalt...
Under section 119(2)(b), delay in filing a return for refund must be examined on reasonable cause, genuine hardship, and any indication of tax evasion. The petitioner supported delayed filing with medical records showing illness of the working partner, and the Court held that this explanation required proper consideration as genuine hardship. Because the return was filed only to claim TDS refund and the treatment documents were not considered, the rejection was found mechanical and erroneous. The condonation refusal was set aside, and the return was directed to be treated as filed within time.
Under section 119(2)(b), delay in filing a return for refund must be examined on reasonable cause, genuine hardship, and any indication of tax evasion. The petitioner supported delayed filing with medical records showing illness of the working partner, and the Court held that this explanation required proper consideration as genuine hardship. Because the return was filed only to claim TDS refund and the treatment documents were not considered, the rejection was found mechanical and erroneous. The condonation refusal was set aside, and the return was directed to be treated as filed within time.
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