Electronic return filing impediment and positive gross total income threshold justify interim permission to submit a paper return.

The article notes that interim relief may be available where the electronic filing utility prevents submission of a return despite a prima facie claim based on positive gross total income. The claimed deduction was examined with reference to section 80-IE and the Chapter VI-A scheme, and positive gross total income was treated as the relevant threshold for the deduction claim. The software's inability to accept the return was treated as a practical impediment, and the pending constitutional challenge to Rule 12 of the Income-tax Rules supported notice and an interim arrangement. The petitioner was permitted, in the interim, to file a paper return pending final disposal of the writ petition.

---

---

Issues: Whether, pending the writ petition, the petitioner should be permitted to file a paper return of income for assessment year 2022-23 where the electronic utility would not accept the return, and where the claimed deduction under Chapter VI-A was said to be available if the gross total income was positive.

Analysis: The permitted claim was examined in the light of the statutory scheme under section 80-IE of the Income-tax Act, 1961, and the comparable treatment of deductions under Chapter VI-A. The positive gross total income was treated as the relevant threshold for the claimed deduction, and the inability of the software to accept the return because of the manner in which the utility was programmed was taken as a practical impediment warranting interim protection. The existence of a constitutional challenge to the vires of Rule 12 of the Income-tax Rules also supported issuance of notice and interim arrangement.

Conclusion: The petitioner was permitted, in the interim, to file a paper return of income pending final disposal of the petition.

Ratio Decidendi: Where the electronic filing utility prevents presentation of a return notwithstanding a prima facie claim founded on a positive gross total income, interim relief may be granted to enable filing of a paper return pending adjudication of the writ petition.

---