Bona fide delay in filing income-tax return warrants condonation where supported by sufficient cause and a justice-oriented approach.

Delay in filing the income-tax return for assessment year 2022-23 was condoned because the explanation for late filing, based on finalisation of accounts and preparation of financial statements in anticipation of merger-related proceedings, was found bona fide and adequately supported. Applications under Section 119(2)(b) of the Income-tax Act, 1961 require a justice-oriented assessment rather than a pedantic one, and sufficient cause supported by the record warrants condonation. The rejection order was therefore unsustainable.

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Issues: Whether the delay in filing the return of income for assessment year 2022-23 was liable to be condoned under Section 119(2)(b) of the Income-tax Act, 1961.

Analysis: The delay was explained as arising from finalisation of accounts and preparation of financial statements in anticipation of merger-related proceedings. The explanation was found to be bona fide and adequately supported. In considering applications for condonation under Section 119(2)(b), the authorities are required to adopt a justice-oriented approach rather than a pedantic one.

Conclusion: The delay in filing the return of income was rightly condoned, and the rejection order was unsustainable.

Ratio Decidendi: Applications for condonation of delay under Section 119(2)(b) of the Income-tax Act, 1961 must be decided on a justice-oriented assessment of the explanation offered, and a bona fide delay supported by sufficient cause warrants condonation.

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