CBDT Must Give Fair Hearing on 1585-Day Delay in Revised Return Filing Despite Section 119(2) Being Silent.

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....HC set aside order denying condonation of 1585-day delay in filing revised return under s.139(5), holding principles of natural justice must be followed despite absence of explicit provision in s.119(2). Natural justice principles should be read into statutory gaps when not explicitly excluded. Matter remanded to CBDT for fresh consideration with directions to provide petitioner hearing opportunity and issue reasoned order within three months. While s.119(2) doesn't specify procedural requirements, decisions with serious civil consequences warrant fair hearing. CBDT must evaluate condonation application afresh following due process, keeping merits open for consideration.....