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HC allowed the petition, finding that the accountant's inadvertent error should not prejudice the taxpayer's substantive rights. The court held that under Section 119(2)(b), the revenue authority was duty-bound to exercise discretionary jurisdiction liberally, considering the bona fide nature of the delay. While interest on the refund was denied per CBDT Circular No. 9 of 2015, the court directed the respondent to process the income tax return and refund the principal amount. The decision emphasized that technical delays should not result in unjust enrichment of the revenue department, particularly when the taxpayer's substantive entitlement is uncontested.
HC allowed the petition, finding that the accountant's inadvertent error should not prejudice the taxpayer's substantive rights. The court held that under Section 119(2)(b), the revenue authority was duty-bound to exercise discretionary jurisdiction liberally, considering the bona fide nature of the delay. While interest on the refund was denied per CBDT Circular No. 9 of 2015, the court directed the respondent to process the income tax return and refund the principal amount. The decision emphasized that technical delays should not result in unjust enrichment of the revenue department, particularly when the taxpayer's substantive entitlement is uncontested.
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