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    <title>2024 (8) TMI 938 - DELHI HIGH COURT</title>
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    <description>The Delhi HC quashed reassessment notices u/s 148 for AY 2013-14 and 2014-15. The court held that failure to electronically upload Form 10CCB was merely a directory procedural requirement and could not establish income escapement. For AY 2013-14, the reassessment was time-barred under Section 149, being beyond the six-year limit. The court ruled that prior to Finance Act 2020 amendments, Section 80-IA(7) only required furnishing audit reports with returns, not electronic submission. As long as reports were available for scrutiny during assessment proceedings, the provision was substantially fulfilled. Electronic filing failure was not fatal to Section 80-IA(7) claims.</description>
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      <title>2024 (8) TMI 938 - DELHI HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=757234</link>
      <description>The Delhi HC quashed reassessment notices u/s 148 for AY 2013-14 and 2014-15. The court held that failure to electronically upload Form 10CCB was merely a directory procedural requirement and could not establish income escapement. For AY 2013-14, the reassessment was time-barred under Section 149, being beyond the six-year limit. The court ruled that prior to Finance Act 2020 amendments, Section 80-IA(7) only required furnishing audit reports with returns, not electronic submission. As long as reports were available for scrutiny during assessment proceedings, the provision was substantially fulfilled. Electronic filing failure was not fatal to Section 80-IA(7) claims.</description>
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