Exim Infrastructure India (P) Ltd. v. CBDT(2026) 349 CTR 210 / 181 taxmann.com 12 (Orissa)(HC)

S. 119: Central Board of Direct Taxes-Circular-Return of income-Condonation of delay-Successive resignation of employees handling accounts and income tax-related compliances causing delay in filing return of income constituted a reasonable cause-The authorities should adopt a liberal approach and condone the delay considering genuine hardships and the plight of the assessee. [S.139, Art.226].

Principal Commissioner rejected the reason provided by the assessee that its employees handling accounts and tax matters left employment in quick succession and refused to condone the delay in filing its return of income. However, the High Court accepted the reasons and allowed the petition, directing the PCIT to condone the delay and also held that by dint of circulars issued by the Central Board of Direct Taxes, the power to condone the delay being vested in the statutory authorities, they should adopt a liberal approach in considering the plight of the assessee. (AY. 2024-25)

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