Condonation of minimal filing delay requires pragmatic hardship-based review before denying carry forward of loss relief.

A minimal and bona fide delay in filing a return may warrant condonation where refusal would unjustly deny consequential tax relief such as carry forward of loss. The Court applied Section 119(2)(b) of the Income-tax Act, 1961 and CBDT Circular No. 11 of 2024, holding that the authority must assess genuine hardship and proportionality pragmatically rather than adopt a mechanical approach. On the facts, the 7-day delay was treated as negligible, the denial of relief was found inconsistent with the statutory scheme, and the return was required to be processed in accordance with law.

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Issues: Whether a delay of 7 days in filing the return, leading to denial of carry forward of loss, was liable to be condoned and the return processed in the light of Section 119(2)(b) of the Income-tax Act, 1961 and CBDT Circular No. 11 of 2024.

Analysis: The return had been filed only 7 days beyond the due date, and the delay was treated as negligible and bona fide. The refusal to entertain the claim for carry forward of loss was found to rest on an erroneous reading of the statutory scheme and the circular. The Court applied the principles governing condonation of delay, including genuine hardship and proportionality, and held that the assessing authority ought not to have declined relief in such circumstances.

Conclusion: The delay was required to be condoned, and the return was directed to be processed in accordance with law.

Ratio Decidendi: Where the delay in filing a return is minimal and bona fide, and the statutory power under Section 119(2)(b) of the Income-tax Act, 1961 is attracted, the authority must consider condonation pragmatically in light of genuine hardship and proportionality rather than mechanically deny consequential tax relief.

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