https://www.taxtmi.com/caselaws?id=798688 Discretionary relief under Section 119(2)(b) requires a contextual assessment of special circumstances rather than application of a predetermined formula. Taxing the same interest income in two assessment years after a deductor revised Form 26AS creates genuine hardship where the taxpayer promptly pursued rectification and revision remedies. Delay substantially attributable to pending or rejected remedial proceedings should not defeat relief. Refusing condonation in those circumstances would retain tax paid twice on the same income and result in unjust enrichment of the Revenue. A revised return for the relevant assessment year may be permitted, subject to verification in accordance with law. en-us Mon, 07 Sep 2026 00:00:00 +0530 Thu, 10 Sep 2026 08:51:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798688 Discretionary relief under Section 119(2)(b) requires a contextual assessment of special circumstances rather than application of a predetermined formula. Taxing the same interest income in two assessment years after a deductor revised Form 26AS creates genuine hardship where the taxpayer promptly pursued rectification and revision remedies. Delay substantially attributable to pending or rejected remedial proceedings should not defeat relief. Refusing condonation in those circumstances would retain tax paid twice on the same income and result in unjust enrichment of the Revenue. A revised return for the relevant assessment year may be permitted, subject to verification in accordance with law. Case-Laws Income Tax Mon, 07 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798688