Writ relief against show cause notices is available where jurisdiction is absent and concluded advance rulings cannot be reopened without fresh fraud ...
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The ITAT held that the return-filing condition introduced in section 80AC(ii), requiring a return to be filed within the time prescribed under section 139(1), applied only from 1 April 2021 and was not applicable to assessment year 2019-20. Accordingly, denial of deduction under section 80P in an intimation under section 143(1) solely because the return was filed belatedly was unsustainable, and the intimation was annulled.
The ITAT held that the return-filing condition introduced in section 80AC(ii), requiring a return to be filed within the time prescribed under section 139(1), applied only from 1 April 2021 and was not applicable to assessment year 2019-20. Accordingly, denial of deduction under section 80P in an intimation under section 143(1) solely because the return was filed belatedly was unsustainable, and the intimation was annulled.
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