Case Law Details
Balaji Super Alloys Vs PCIT (Madras High Court)
In a significant ruling, the Madras High Court condoned a mere 21-second delay in filing an income tax return (ITR) by the petitioner, Balaji Super Alloys. The case involved the Principal Commissioner, Coimbatore, who initially rejected the petitioner’s deduction claim under Section 80IA due to the minor delay.
The petitioner filed its income tax return at 00.00.21 am on 16th February 2021, just 21 seconds after the deadline. Despite this minimal delay, the return was considered late, and a deduction under Section 80IA was disallowed, resulting in a consequential demand. The petitioner’s request to condone the delay was initially rejected, leading to the filing of the writ petition.
The court, noting the negligible delay, ruled in the petitioner’s favor, considering it a human error that should be condoned in the interests of substantial justice. The court also observed that while the return filing software is programmed to close the portal at midnight, the condonation request should have been considered by a human who could recognize the minor delay’s exceptional nature.
However, the court also underlined the importance of adhering to deadlines, cautioning the petitioner to ensure timely compliance with statutory requirements to avoid such issues in the future.
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