2021 (4) TMI 596

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....an Ray For the Income Tax Authorities ORDER The petitioner made two separate applications under Section 119(2)(b) of the Income Tax Act, 1961 (hereinafter referred to as the "said Act") for condoning the delay and accepting the return for the assessment years 2015-16 and 2016-17. The petitioner says that the return for the assessment year 2016-17 has been accepted by condoning the delay. However....

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....t invoking the writ jurisdiction. The petitioner says that the authorities may be directed to consider the petitioner's application for condoning the delay and accepting the return for the assessment year 2015-16 in a lenient and justice-oriented approach. The petitioner relies upon the judgments delivered in Bombay Mercantile Co-op. Bank Ltd. v. Central Board of Direct Taxes, reported in [2010] ....

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....ces, I am of the view that the department ought to have taken a justice-oriented approach instead of taking a highly pedantic approach in refusing to condone the delay on the part of the petitioner in filing the return for the assessment year 2015-16. The order dated 25th August, 2020 passed by the Principal Chief Commissioner of Income Tax (International Taxation), being the respondent no.1, in r....