Income Tax Return Delays: High Court Rules on Tax Authority's Decision-Making Boundaries

Condonation of delay: focus on admissibility of the request, not the substantive merits of the tax claim.

The legal principle requires that the authorized officer considering a condonation application under Section 119(2)(b) confine inquiry to the admissibility of the request and the justification for delay; assessment of the substantive merits of the taxpayer's income or loss claim is not part of the condonation exercise, and evidentiary review is limited to matters relevant to excusing the delay.