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The HC allowed the petitioner's application under section 119(2)(b) for condonation of delay in filing Form 67 under Rule 128. The petitioner had received salary income from Bangladesh with tax duly paid but failed to submit the required Form 67 before the return filing due date. Despite the Department Representative arguing no genuine hardship was demonstrated, the HC held that filing forms for claiming statutory benefits is procedural in nature, following established precedents. The Court distinguished this case from technical non-compliance situations, emphasizing that procedural requirements should not defeat substantive rights when the underlying tax obligation was properly discharged. The assessee's appeal was allowed, granting relief from the delayed form submission.
The HC allowed the petitioner's application under section 119(2)(b) for condonation of delay in filing Form 67 under Rule 128. The petitioner had received salary income from Bangladesh with tax duly paid but failed to submit the required Form 67 before the return filing due date. Despite the Department Representative arguing no genuine hardship was demonstrated, the HC held that filing forms for claiming statutory benefits is procedural in nature, following established precedents. The Court distinguished this case from technical non-compliance situations, emphasizing that procedural requirements should not defeat substantive rights when the underlying tax obligation was properly discharged. The assessee's appeal was allowed, granting relief from the delayed form submission.
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