Delhi High Court Sets Precedent: Genuine Taxpayer Hardship Cannot Be Ignored

Delhi High Court Sets Precedent: Genuine Taxpayer Hardship Cannot Be Ignored

Facts of the case

The petitioner missed the deadline to file ‘Form 10IC’ for the 2023-24 assessment year, which prevented them from accessing certain tax benefits. When they asked the commissioner to forgive this delay, the request was flatly denied because that specific year wasn’t explicitly listed in the latest CBDT circular.

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Issue of the case

Whether tax authorities could hide behind a narrow, literal reading of a circular to deny help, even when the taxpayer had a genuine case of hardship?

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Decision of the Delhi High Court

The Delhi High Court ruled that a circular intended to fix “genuine hardship” shouldn’t be limited to the specific years written on the page. Instead, the spirit of the law matters more: if the intent is to help in honest cases, that help should extend to everyone, regardless of the year.