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TMI Blog2025 (1) TMI 1129X X X X Extracts X X X X X X X X Extracts X X X X ..... espondents: Mr Dinesh R Gulabani a/w Mr. Vibhor D Gulabani,. ORAL JUDGEMENT :- (PER M.S. SONAK, J ) 1. Heard Ms. Aadnya Bhandari and Mr. Nishit Gandhi for the Petitioner and Mr. Gulabani for the Respondents. 2. Rule. The rule is made returnable immediately at the request of and with the consent of learned counsel for the parties. 3. This Petition concerns the Assessment Year 2022-23 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... etitioner trust was old and presumed to know the rules and regulations. He pointed out that this reconstruction and redevelopment did not prevent the Petitioner trust from undertaking its routine activities. Therefore, this reason could not now be cited as a cause for not filing Form-10B within the prescribed limitation period. He referred to the decisions discussed in the impugned order regarding ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... se of sufficient cause was made out. 8. The impugned order notes that if the condonation had pertained to F.Y.2018-19, then the reason now cited by the trust could have been accepted. However, since the delay pertains to A.Y. 2022-23, this cause cannot be accepted. Since there is no dispute that the reconstruction and redevelopment work commenced in 2018 and were ongoing, such a distinction was i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... xpected to consider the cause shown. In a matter where the delay is not inordinate, the liberal approach could be adopted. 10. Even assuming that in tax matters, the liberal approach should not be readily adopted given the importance of the timelines, still, even on a conservative basis, this is a matter where sufficient cause has been shown to explain the marginal delay. 11. For all the above r ..... X X X X Extracts X X X X X X X X Extracts X X X X
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