Assessee, a cooperative society registered under Odisha Cooperative Societies Act, 1962 (OCS Act). Assessee was required to get its accounts audited under section 62 of the OCS Act in order to file its return and claim deduction under section 80P.Due to acute shortage of departmental auditors and failure of the Auditor-General of Cooperative Societies (AGCS) to appoint/authorise auditors in time, audit could not be completed within the prescribed period. Said shortage resulted in failure to file returns and audit reports within the due date under section 139(1) . Assessee-society filed application for condonation of delay. However, Principal Chief Commissioner rejected the application, holding that the assessee was a habitual non-filer and that no genuine hardship had been established. On writ, the Court held that delay in completion of audit by auditor appointed under the Act was not attributable to the assessee, and there was default on the part of AGCS; accordingly, the Principal Chief Commissioner should have considered the application under section 119(2)(b) appropriately by allowing the assessee to avail the benefit of section 80P of the Act. (AY.  2018-19 to 2022-23)