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The authorities concerned were instructed to process the return in accordance with law, ensuring no prejudice was caused to the taxpayer on account of technical non-compliance..

The Department must act within the stipulated ten-week period, failing which further remedial measures may be sought by the petitioner..

Furthermore, the reaffirmation of the principles laid down in Engineering Analysis provides clarity on the tax treatment of payments made to foreign entities for interconnectivity services, confirming that such payments are not automatically to be treated as royalty or FTS for TDS purposes unless there is a clear transfer of intellectual property or technical know-how..

In cases where the trust’s activities are religious in nature, the benefit under Section 80G cannot be extended, irrespective of 12AA registration..

Taxpayers should ensure timely compliance with the deposit directive to maintain protection against coercive action..

Routine or mechanical issuance of notice, without application of mind or proper evaluation of the assessee’s contentions, will render the reopening liable to be quashed..

This conclusion provides a definitive guideline for similar matters, underscoring the importance of strict adherence to limitation periods, especially in light of Supreme Court rulings..

Taxpayers similarly placed should ensure timely documentation of hardship and demonstration of bona fide conduct to avail of such condonation..

Consequently, the writ petitions were dismissed, reaffirming the enforceability of the amended TDS provisions..

The Court's decision provides an actionable directive for tax administrators to strictly adhere to the limitation provisions and for taxpayers to challenge notices issued beyond the prescribed period..