Assessee, a Singapore based company, approached Authority for Advance Rulings (AAR) in relation to its three projects and authority provided a ruling to effect that income earned from said three projects were not taxable in India. With regard to three other projects relating to assessment years 2012-13, 2013-14 and 2014-15, respectively, assessee again approached AAR and requested for a ruling with regard to tax liability in India. After receipt of ruling that income was taxable in India, assessee filed return. Assessee filed application for condonation of delay, however same was rejected. On writ the assessee claimed that it experienced difficulty in filing returns because digital signature certificate (DSC) of one of foreign directors could not be obtained easily and eventually, returns in respect of all three assessment years were filed in March 2017.The assessee claimed that it did not file return prior to due dates on bona fide belief that application for advance ruling would be held to be not maintainable as per section 245R(2). The Court held that assessee’s assertion that it could lose valuable right of requesting for an advance ruling by filing returns of income while applications were pending before AAR could not be disregarded as lacking credibility.In view of facts that applications fell within scope of expression genuine hardship in section 119(2)(b), delay in filing returns of income seeking refund were liable to be condoned. (AY. 2012-13, 2013-14)(SJ)