2024 (8) TMI 48

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....Mr. J. Saravanan For the Respondents : Mr. D. Prabhu Mukunth Arunkumar , Junior Standing Counsel ORDER These writ petitions challenge the orders rejecting applications under Section 119(2)(b) of the Income Tax Act, 1961 (the Income Tax Act). 2. The petitioner is a resident of the United States of America. He is assessed to tax in India and filed his return of income in India. In the fi....

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....etitioner realized that a large amount was deducted at sources for the relevant assessment years and that he was entitled to refund. Therefore, applications were filed before the Commissioner of Income Tax under Section 119(2)(b) of the Income Tax Act seeking condonation of delay. The said applications were dismissed by orders impugned herein. 4. Learned counsel for the petitioner submits that ....

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....genuine hardship. The said provision has been interpreted in several judgments, including of this Court, and it has been held that the provision should receive a liberal construction. The primary consideration in such applications is whether genuine hardship would be caused to the applicant. In this case, the applicant is an individual assessee. He resides in the United States of America. The two ....