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The HC set aside the impugned order and remitted the matter to the concerned PCIT for de novo consideration of the applicant's condonation request under s.119(2)(b). The court held the PCIT, exercising quasi-judicial powers, acted mechanically by failing to address the applicant's averments and did not issue a reasoned order; consequently the rejection was unsustainable. The HC directed the PCIT to evaluate genuine hardship on merits, taking into account that the return was filed with only a twelve-day delay and the factual matrix pleaded by the applicant, and to pass a fresh, reasoned decision in accordance with law.
The HC set aside the impugned order and remitted the matter to the concerned PCIT for de novo consideration of the applicant's condonation request under s.119(2)(b). The court held the PCIT, exercising quasi-judicial powers, acted mechanically by failing to address the applicant's averments and did not issue a reasoned order; consequently the rejection was unsustainable. The HC directed the PCIT to evaluate genuine hardship on merits, taking into account that the return was filed with only a twelve-day delay and the factual matrix pleaded by the applicant, and to pass a fresh, reasoned decision in accordance with law.
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