Impossibility of compliance with statutory return filing bars coercive action where the prescribed form prevented lawful filing.

Coercive action for non-filing of the FC-4 return was restrained because the amended return format and supporting online mechanism made compliance impossible for the relevant period. The Court noted that the prescribed form accepted only an account maintained at a specified SBI branch in New Delhi, while the notification identifying that branch was issued later, creating a genuine filing difficulty despite lawful conduct by the registered foreign contribution recipients. A person cannot be penalised for non-compliance where a defect in the statutory form or its mechanism makes lawful compliance impossible.

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Issues: Whether coercive action could be taken against the petitioners for non-filing of the FC-4 return where the prescribed form and the amended account requirement made compliance impossible for the relevant period.

Analysis: The petitioners were registered recipients of foreign contribution and were required to file the return under the statutory scheme governing foreign contributions. The return format had been altered by amendment, and the online form accepted only an account maintained at the specified SBI branch in New Delhi, while the notification identifying that branch was issued later. On the material placed before the Court, this created a genuine compliance difficulty for the relevant return period. The Court found that a citizen should not be penalised for a discrepancy in the prescribed form that made filing impossible despite lawful conduct.

Conclusion: Coercive action for failure to file the FC-4 return by the stipulated date was restrained in favour of the petitioners.

Ratio Decidendi: A person cannot be penalised for non-compliance with a statutory form when the defect in the form or its supporting mechanism makes lawful compliance impossible.

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