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TMI Blog2019 (6) TMI 1224X X X X Extracts X X X X X X X X Extracts X X X X ..... it petition itself is taken up, heard out and is being disposed of. 3.The entire matter turns on a very narrow compass. 4. Writ petitioner is a foreign company incorporated under the laws of Singapore and therefore a tax resident of Singapore. Petitioner company is engaged in the business of heavy lifting, erection and primarily carries out work relating to various refineries projects in several countries in Asia and in the Gulf region. 5. Under the aforesaid circumstances, writ petitioner filed three different applications before Authority for Advance Ruling seeking its ruling in respect of three different projects undertaken by the writ petitioner and query for which ruling from the 'Advance Ruling Authority' ('ARA' for ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2013 to 31.03.2014 Previous Year relevant to Assessment Year 2014-15 2 11.04.2014 Applications filed before Authority for Advance Ruling in respect of the Projects viz., (1) Larsen & Toubro, Punjab and (2) Punj Lloyd Ltd., Karnataka 3 13.06.2014 Application field before Authority for Advance Ruling in respect of the project viz., GR Engineering Pvt. Ltd., 4 30.11.2014 Due date for Return for AY.2014-15 5 16.08.2016 Authority for Advance Ruling pronounced Ruling-Income to be computed u/s.44BB of Income Tax Act, 1961 6 06.03.2017 Return filed claiming refund Rs. 9,33,290/- 7 16.03.2017 Petition u/s.119(2)(b) for Condoning of Delay in filing return 8 07.03.2019 Impugned order of Respondent rejecting the pet ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... gned order. If the delay is condoned and if the returns filed by the writ petitioner is scrutinized, it will balance the rights of the parties and serve the ends of justice. 10. Therefore, in the light of narrative thus far, this Court passes the following order: a) impugned order of respondent dated 07.03.2019 will stand set aside subject to the condition that the writ petitioner pays a sum of Rs. 10,000/- (Rupees Ten Thousand only) towards costs to Blue Cross of India, No.72, Velachery Road, Guindy, Chennai - 32 within two weeks from today i.e., on or before 01.07.2019; b) On aforesaid costs being paid and condition being complied, post 01.07.2019, the delay shall stand condoned and the respondent shall take up the returns filed by t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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