Condonation of Delay under Section 119(2)(b) – CBDT Circular Cannot Override Substantive Right to Refund: HC   Santhana Krishnan (WP No. 21071 of 2025) Facts: 1.  Petitioner is a Non-Resident Indian (resident of United States) who sold immovable property in FY 2022–23 and deducted & remitted tax, but failed to file return u/s 139. 2. …

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