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TMI Blog2022 (11) TMI 1174X X X X Extracts X X X X X X X X Extracts X X X X ..... eeking to invoke section 139(1) Explanation-2 (c) of the Act. A perusal thereof makes it clear that it is in the nature of residuary clause dealing with any other assessee whereas this taxpayer is found to be covered u/s. 139(1) Explanation-2(a)(ii) thereof as applicable in case of a person [other than company] whose accounts are required to be audited under this Act or under any other law for ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... -21/1031168590(1) and in DIN Order No. ITBA/NFAC/S/250/2020-21/1031169031(1); respectively, in proceedings under section 143(1) of the Income Tax Act, 1961 [In short the Act ]. 2. Heard both the parties. Case files perused. 3. It emerges during the course of hearing that assessee s identical source of standing grievance lies in a very narrow compass. Both the lower authorities have disall ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... st July to 31st August. The assessee seems to have confused itself about the extension in due dates, ignoring the fact that it is not covered under cl (a) but is covered under cl (c) of Expl 2 to sec 139(1). The argument of the appellant therefore does not hold water on facts. There is no further extension of due date for filing returns beyond 31/08/2018 to any assessees covered by cl (c) of Exp I ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nts seeking to invoke section 139(1) Explanation-2 (c) of the Act. A perusal thereof makes it clear that it is in the nature of residuary clause dealing with any other assessee whereas this taxpayer is found to be covered u/s. 139(1) Explanation-2(a)(ii) thereof as applicable in case of a person [other than company] whose accounts are required to be audited under this Act or under any other law ..... X X X X Extracts X X X X X X X X Extracts X X X X
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