Court Dismisses Petition on 3-Year Delay in Tax Return Filing; CBDT Rejection Upheld u/s 119.

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....Delay in filing of return - Condonation of delay of 3 years, 2 months and 6 days in filing the original return - CBDT rejected the application u/s 119 - Even a declaration of loss would require assessment so that only the genuine loss is recognised and which would be available for carry forward to be set off against future income or to claim refund. Accepting petitioner’s request for such a huge delay would amount to re-opening the assessment of AY-1998-1999 in AY-2023-2024. - Petition dismissed - HC....