2024 (10) TMI 177

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....T YADAV FOR THE PETITIONER: SRI. A. SHANKAR, SENIOR ADVOCATE FOR SRI. MADHUSUDHAN U.A, ADVOCATE FOR THE RESPONDENTS: SRI. Y.V. RAVIRAJ, SR. STANDING COUNSEL AND SRI. M. DILIP, JR. STANDING COUNSEL ORDER The petitioner has challenged the order under Section 119(2)(b) of the Income Tax Act, 1961 (for short 'the Act') at Annexure-'A' passed by respondent No.1 for the assessment y....

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....delay ought to be condoned taking note of the circular dated 09.06.2015, wherein the provision for condonation is extended to six years and restriction if any is regarding condonation of delay beyond six years. 3. Learned counsel Sri. Ravi Raj Y. V., appearing for the revenue on the other hand submits that the decision on application under Section 119(2)(b) of the Act ought to be made by the auth....

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....rdingly, we set aside the order under Section 119(2)(b) of the Act as the Court also finds that the authority has taken a very restrictive and conservative approach while dealing with Section 119(2)(b) of the Act, in not noticing the directions of the Central Board of Direct Taxes (CBDT) regarding condonation up to six years. Matter is remitted back to respondent No.1 to reconsider the matter. Whi....