Transfer-pricing comparability filters require fresh arm's-length analysis, while delayed receivables need separate reconsideration with working-capit...
Section 153C jurisdiction requires timely deemed search and assessee-specific satisfaction material; otherwise reassessment must use the proper statut...
Credit-note turnover adjustments preserve inverted-duty refunds, while ministerial re-computation does not constitute an impermissible appellate reman...
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Belated electronic filing of Form No. 9A for deemed application of charitable income may be condoned where substantial compliance and sufficient cause are established. The administrative condonation remedy under section 119(2)(b) is additional and does not bar appellate consideration of an exemption claim after administrative condonation is refused. Filing during assessment proceedings in the first year of mandatory electronic filing, without evidence of deliberate or mala fide delay, supported condonation of the short delay. The delayed Form No. 9A was treated as valid, and the deemed-application claim was directed to be considered after verification of the remaining statutory conditions and a hearing.
Belated electronic filing of Form No. 9A for deemed application of charitable income may be condoned where substantial compliance and sufficient cause are established. The administrative condonation remedy under section 119(2)(b) is additional and does not bar appellate consideration of an exemption claim after administrative condonation is refused. Filing during assessment proceedings in the first year of mandatory electronic filing, without evidence of deliberate or mala fide delay, supported condonation of the short delay. The delayed Form No. 9A was treated as valid, and the deemed-application claim was directed to be considered after verification of the remaining statutory conditions and a hearing.
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