HC allowed the writ petition filed by the assessee-company, holding that the delay of about 17 months in filing the revised/rectified return of income, based on a revised tax audit report, was satisfactorily explained and attributable to circumstances beyond the assessee's control due to the COVID-19 pandemic. HC noted the assessee's past compliance history, timely filing of the original return for AY 2018-19, and the favourable recommendations of the Jurisdictional AO and Range Head for condonation under s.119(2)(b). HC held that a justice-oriented rather than pedantic approach must govern such applications. Consequently, the impugned order rejecting condonation was quashed and set aside, the delay was condoned, and any demand/recovery/adjustment arising from the intimation u/s 143(1) was directed not to be proceeded with.
HC allowed the writ petition filed by the assessee-company, holding that the delay of about 17 months in filing the revised/rectified return of income, based on a revised tax audit report, was satisfactorily explained and attributable to circumstances beyond the assessee's control due to the COVID-19 pandemic. HC noted the assessee's past compliance history, timely filing of the original return for AY 2018-19, and the favourable recommendations of the Jurisdictional AO and Range Head for condonation under s.119(2)(b). HC held that a justice-oriented rather than pedantic approach must govern such applications. Consequently, the impugned order rejecting condonation was quashed and set aside, the delay was condoned, and any demand/recovery/adjustment arising from the intimation u/s 143(1) was directed not to be proceeded with.
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