High Court Affirms Only Assessing Officer Can Condon Delay in Refund Applications u/r 47, Not Deputy Commissioner.

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....Power to condone the delay in filing of refund application - The prescription as found in Rule 47 specifically empowers the Assessing Officer to condone the delay in filing the statement (application) or other documents referred to in clauses (i) to (iv). When a clear prescription has been made as per the statutory provision, Section 20A has no application and in such circumstances, the Deputy Commissioner cannot usurp the powers of the Assessing Officer who has been conferred with the power to condone delay in filing applications. - HC....