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Issues: Whether the petitioners could be permitted to file income-tax returns for the relevant assessment year without furnishing Aadhaar linkage details and whether the tax administration was bound to provide an effective opt-out mechanism for the period covered by the CBDT extension.
Analysis: The Court noted that the CBDT had issued an order under Section 119 of the Income-tax Act, 1961 extending time for linking PAN with Aadhaar. In light of the earlier judicial approach granting limited relief and the continuing extension of time, the Court held that a similar direction was warranted. It further observed that the administration should create a functional platform in the digital return forms to permit filing without Aadhaar linkage during the subsisting exemption period.
Conclusion: The petitioners were permitted to file their returns without insisting on Aadhaar linkage or production of Aadhaar enrolment proof for the relevant period, and the returns were to be processed according to law and the CBDT circular as extended.
Final Conclusion: The writ petition was allowed with directions securing filing and processing of returns despite the temporary absence of Aadhaar linkage, and the tax administration was required to facilitate that position administratively for the duration of the extension.
Ratio Decidendi: Where the competent authority has extended the time for PAN-Aadhaar linkage under Section 119, the return-filing process cannot insist on Aadhaar linkage during the extended period and must be administered consistently with that extension.
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