2024 (10) TMI 177

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....ON'BLE MR JUSTICE S SUNIL DUTT 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....

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.... than six years. It is submitted that the 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....

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....ion under Section 119(2)(b) of the Act. 6. Accordingly, 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 bac....