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    <title>2025 (12) TMI 1584 - BOMBAY HIGH COURT</title>
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    <description>The dominant issue was whether rejection under s.119(2)(b) of the condonation application for an eight-minute delay in e-filing the return, resulting in denial of carry-forward of losses, was valid. The HC held that the audit report under s.44AB was uploaded within time and the taxpayer had logged into the portal before midnight; even assuming no portal glitch, an eight-minute delay was a sufficient cause when refusal would cause grave hardship by disallowing substantial carried-forward losses. The impugned rejection was set aside and the delay in filing the return for the relevant AY was condoned, restoring eligibility to claim carry-forward of losses.</description>
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      <link>https://www.taxtmi.com/caselaws?id=784044</link>
      <description>The dominant issue was whether rejection under s.119(2)(b) of the condonation application for an eight-minute delay in e-filing the return, resulting in denial of carry-forward of losses, was valid. The HC held that the audit report under s.44AB was uploaded within time and the taxpayer had logged into the portal before midnight; even assuming no portal glitch, an eight-minute delay was a sufficient cause when refusal would cause grave hardship by disallowing substantial carried-forward losses. The impugned rejection was set aside and the delay in filing the return for the relevant AY was condoned, restoring eligibility to claim carry-forward of losses.</description>
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      <pubDate>Tue, 16 Dec 2025 00:00:00 +0530</pubDate>
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