Calcutta High Court
For assesseeRemanded
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1 ruling found
Calcutta High Court
Where assessee filed rectification application for ITC after prescribed cut-off as per departmental circulars but statute provided no time limit, executive circulars imposing six-month cap could not override substantive right under Section 16(5), and rejection for delay was unsustainable so rectification application was to be reconsidered on merits unless delay was found exceptional