The assessee, a joint venture executing a civil contract for the Government of Uttar Pradesh, could not receive payments due to a dispute which was referred to arbitration. Pursuant to the arbitral award, payments were received in different tranches and the assessee claimed refund of TDS deducted thereon. The assessee’s application for condonation of delay under section 119(2)(b) was rejected by the CBDT on the ground that it was filed beyond six years. The High Court held that the assessee had been diligent in pursuing its refund claim and that the delay was attributable to the arbitration proceedings, receipt of payments in different tranches and the COVID-19 pandemic. The delay was accordingly condoned and the assessee’s claim for refund was directed to be considered on merits. (AY. 2014-15)