Kotak Family Foundation, a charitable trust registered under Sections 12A/12AA and 80G of the Income -Tax Act, 1961, filed its return for AY 2021–22 on 30th December 2021, within the extended COVID-19 timeline. Form 9A was filed and the audit report in Form 10B was uploaded by the auditor on 29th December 2021. However, due to oversight caused by remote working conditions during the pandemic, the Trust failed to e-verify the audit report within the prescribed time. After receiving an intimation under Section 143(1)(a) on 8th September 2022 denying exemption of ₹58,02,006/-, the Trust  completed e-verification the next day. Although a revised intimation accepted the return, the exemption was again denied by a rectification order under Section 154 dated 7th March 2023. The Trust’s request for condonation of delay was rejected by the Commissioner of Income Tax (E) on 10th February 2025. On writ the   Hon’ble Bombay High Court held that the rejection of the petitioner’s application for condonation of delay in e-verifying Form 10B was unjustified and contrary to the principles of justice, equity, and fair play, particularly considering the petitioner is a registered charitable trust. The delay occurred due to genuine inadvertence during the COVID-19 pandemic, when the trustees and staff were operating remotely, and was neither intentional nor negligent. The Court further observed that CBDT Circulars No. 16/2022 and 16/2024 authorize the Commissioner of Income Tax to condone delays of up to 365 days in filing Forms 10B, 9A, 10, and 10BB for AY 2018–19 onwards. In the present case, the delay—whether considered as 254 days or 101 days after applying the benefit of the Supreme Court’s COVID-related extension in In Re: Cognizance for Extension of Limitation,was well within the condonable limit. Therefore, the authorities were expected to adopt a pragmatic and justice-oriented approach rather than a technical one. The Court held that procedural lapses should not override substantive justice, especially when there was no mala fide intent or negligence by the petitioner. As the audit report was filed on time and only the e-verification was delayed due to COVID-related issues, the authorities should have adopted a fair and practical approach. Denial of exemption under Sections 11 and 12A on such technical grounds was deemed unjust. Referring to its earlier decision in Sau Dwarkabai Tai Karwa Charitable Public Trust v. CIT (E), [2025] 174 taxmann.com 245 ( Bom)( HC), where a similar delay was condoned for the same assessment year, the Court quashed the  order dated 10th February 2025, condoned the delay, allowed the writ petition, and made the rule absolute ( W.P. (L) No. 17883 of 2025, decided on 24-06-2025 ) (AY. 2021 -22)