Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Under section 119(2)(b), delay in filing a return for refund must be examined on reasonable cause, genuine hardship, and any indication of tax evasion. The petitioner supported delayed filing with medical records showing illness of the working partner, and the Court held that this explanation required proper consideration as genuine hardship. Because the return was filed only to claim TDS refund and the treatment documents were not considered, the rejection was found mechanical and erroneous. The condonation refusal was set aside, and the return was directed to be treated as filed within time.
Under section 119(2)(b), delay in filing a return for refund must be examined on reasonable cause, genuine hardship, and any indication of tax evasion. The petitioner supported delayed filing with medical records showing illness of the working partner, and the Court held that this explanation required proper consideration as genuine hardship. Because the return was filed only to claim TDS refund and the treatment documents were not considered, the rejection was found mechanical and erroneous. The condonation refusal was set aside, and the return was directed to be treated as filed within time.
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