S208 Kanjanaickenpatty Primary Agricultural Cooperative Credit Society Ltd. v. Chief CIT (2025) 342 CTR 335 / 245 DTR 144 (Mad)(HC)

S. 119 : Central Board of Direct Taxes-Circular-Return—Condonation of delay—Genuine hardship—Audit report was made available on 9th Sept., 2019 i.e., 5 months prior to the COVID outbreak— No reasonable cause-Rejection of application is up held-Writ petition is dismissed. [S. 119(2)(b), 139, 234F, Art. 226]

Rejecting the writ petition against the condonation of delay in filing of return, the Court held that the Audit report was made available on 9th Sept., 2019 itself and there is no substances in the reason assigned by the assessee on the aspect of delay in receipt of the audit report; further, nothing prevented the assessee to file their return before the said COVID outbreak period; taking into consideration of all these aspects, the respondent had rightly rejected the application filed by the assessee. (AY-2019-20)

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