Revised return condonation for income tax assessment refiled; authority directed to reconsider revised return under applicable law.

Petitioner sought to file a revised income tax return for assessment year 2018-19 to correct an apparent mis declaration of exempt dividend income; the authority had rejected a condonation application relying on an executive circular prescribing a five year outer window for entertaining revised returns. The court found factual support for a bona fide apparent mistake and that rectification efforts fell within the circular's temporal framework, set aside the order refusing condonation, and remitted the matter for reconsideration of the revised return in accordance with law, leaving substantive contentions open.

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Issues: Whether the order rejecting the application for condonation of delay for filing a revised return (under Section 119(2)(b) of the Income-tax Act, 1961 and in light of CBDT Circular No. 11/2024 dated 01.10.2024) should be set aside and the matter remitted for consideration of the revised return for the assessment year 2018-19.

Analysis: The petitioner filed the original return for assessment year 2018-19 and later sought rectification and/or to file a revised return to correct an apparent mis-declaration in Schedule-EI concerning exempt/dividend income. The authority rejected the condonation application relying on CBDT Circular No. 11/2024 which prescribes a five-year limitation from the end of the relevant assessment year for entertaining revised returns under Section 119(2)(b). The Court examined the factual record showing a bona fide, apparent mistake in the exempt income declaration and noted that rectification efforts and grievance communications were made within the five-year period indicated by the circular. The Court did not decide the merits of the revised return content but focused on whether the petitioner should be permitted to have the revised return considered in accordance with law.

Conclusion: The order dated 22.12.2025 rejecting the condonation application is set aside and the matter is remitted to the authority to consider the petitioner's revised return for assessment year 2018-19 in accordance with law. The petition is disposed of and all contentions are kept open.

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