Late income-tax return filing u/s119(2)(b) hardship relief request rejected for lack of genuine hardship, delay condonation denied.

Condonation of delay in filing an income-tax return under s.119(2)(b) was refused because the taxpayer failed to establish "genuine hardship" or "reasonable cause" for belated filing. The HC applied the principle of ignorantia juris non excusat, holding that claimed illiteracy and lack of awareness of tax law could not justify non-compliance, particularly since the taxpayer had timely filed a return for an earlier assessment year, evidencing knowledge of the process. Relying on precedent that statutory timelines must be strictly adhered to and extension is not a vested right, the HC upheld the impugned rejection and dismissed the writ petition.

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1. ISSUES PRESENTED AND CONSIDERED

(i) Whether the petitioner established "genuine hardship" and a specific reasonable cause justifying condonation of delay under Section 119(2)(b) for filing the return for the relevant assessment year.

(ii) Whether the reasons advanced-unawareness of tax/TDS, health issues, and COVID-related travel restrictions-were legally and factually sufficient to warrant interference with the rejection order.

(iii) Whether the impugned rejection order suffered from any infirmity warranting writ interference, including on the touchstone of consideration of contentions and the applicable approach to statutory time limits.

2. ISSUE-WISE DETAILED ANALYSIS

Issue (i) & (ii): Existence of "genuine hardship" / reasonable cause for condonation under Section 119(2)(b)

Legal framework (as discussed by the Court): The Court proceeded on the basis that condonation under Section 119(2)(b) is not automatic and is available only when "genuine hardship" is shown. The Court accepted the approach that statutory time limits must be respected and that condonation is justified only on compelling reasons, not on routine or vague assertions.

Interpretation and reasoning: The Court found no merit in the plea that the petitioner's alleged lack of awareness of Indian tax laws justified the delay, applying the principle that ignorance of law is no excuse. The Court also endorsed the reasoning that COVID-related travel restrictions did not satisfactorily explain non-filing because the return could be filed online without physical presence in India. As to health reasons, the Court accepted the finding that the relied-upon surgeries were too remote in time (over a decade earlier) to credibly explain the delay for the relevant year. The Court further noted that the application seeking condonation was made in June 2025 for an assessment year 2020-21 return, and the authority's conclusion that no extraordinary or compelling circumstance was established was supported by reasons recorded in the order.

Conclusion: The petitioner failed to establish "genuine hardship" or any specific reasonable cause for the delayed filing; the grounds urged were insufficient and did not justify condonation.

Issue (iii): Whether the rejection order warranted writ interference

Legal framework (as applied by the Court): The Court treated adherence to statutory timelines as a significant consideration and accepted that extension/condonation cannot be claimed as a vested right. It relied on its own approach in earlier decisions that an authority's rejection should not be interfered with where the order is reasoned and reflects due consideration of the explanations offered.

Interpretation and reasoning: The Court "concurred" with the view taken in the impugned order, expressly finding no reason to interfere. It accepted that the authority had rejected the condonation request with recorded reasons and that the petitioner's principal submission (illiteracy/unawareness) was not persuasive. The Court's reasoning proceeded on the basis that the authority's assessment of the explanations (unawareness of TDS, COVID travel issues, and health grounds) was justified, and therefore the rejection was not infirm.

Conclusion: No ground for writ interference was made out; the rejection order was upheld and the petition dismissed as being without merit.

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