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Issues: Whether rejection of the application for condonation of delay in filing revised returns for claiming exemption on ex gratia compensation was sustainable.
Analysis: The application required a pragmatic and liberal consideration of genuine hardship. Consistent relief granted to identically placed retirees, including condonation of delay, had not been properly considered, notwithstanding that those decisions had attained finality.
Conclusion: The rejection of condonation was unsustainable and was set aside in favour of the assessee.