IN THE HIGH COURT OF DELHI AT NEW DELHI
CIVIL WRIT JURISDICTION
WRIT PETITION (C) No. _____ OF 2018
IN THE MATTER OF:
Northern India CA Federation ...Petitioner
Vs.
Central Board of Direct Taxes ...Respondent
DATE WISE SYNOPSIS
Background: Petitioner is a Non Government
Organization (NGO) registered under the provisions
of Societies Registration Act, 1860 established to
promote and protect the interest of Chartered
Accountants (CA) amongst the CA fraternity of
Northern India. It aims at promoting the interest of
CAs, interalia, by way of conducting educational
training programs; providing regular updates in the
matters of accounting, auditing, taxation etc.
Members of petitioner / assessee are professional
Chartered Accountants.
01/10/2015 Hon'ble Revenue secretary acknowledging the
concerns of Chartered Accountants of inordinate
delay on part of revenue in issuance of forms; utilities
etc required for preparation & filing of e-Returns of
Income including Tax audit reports issued a
statement by way of twitter that all the forms; etc
required for preparation of return of incomes
including finalizing of tax audits will be notified well in
advance from forthcoming years.
31/03/17 Finance Bill 2017 applicable for Financial Year 2017-
18 (Assessment Year (AY) 2018-19) passed by the
Parliament.
01/04/18 As mandated by Hon'ble Division benches of various
High Courts (detailed infra) and as also accepted by
the revenue, all the final Forms, utilities, notifications
etc required for preparation & filing of Returns of
Income for AY 2018-19 were to be notified & finalized
latest by this date being the first date of AY 2018-19.
However, nothing could be done till this date by the
Respondent.
14/04/18- Only the first base version utility uploaded in the web
21/05/18 site of Income department required for e-filing the
Return of Incomes.
Various Innumerable changes made by the Income tax
dates from department in the base utility version required for e-
20/04/18- filing tax returns. A total of 306 changes (app.) made
19/09/18 during this time as summarized in Annexure P9.
Various That thereafter on these various dates also
dates i.e. innumerable changes made in the Tax audit
20/07/18; reporting requirements i.e. Form No. 3CA & 3CD.
01/08/18; Total of such changes made being 100 (app.) in No.
20/08/18; as summarized in Annexure P7 being an admitted
01/09/18 & position by the Income tax department itself vide its
07/09/18. Form 3CD-Schema Change Document dated
07/09/18 (Annexure P8).
20/07/18 Yet another notification prescribed by CBDT in
connection with tax audits required for filing return by
30/09/18.
26/07/18 Order u/s 119 of Income tax Act, 1961 (`the Act')
issued by CBDT extending the timeline of filing
Return of Income in case of certain category of
taxpayers (being essentially individuals drawing
income from salary or individuals not subject to tax
audit) from 31/07/18 to 31/08/18.
22/08/18 Implementation guide issued by the Institute of
Chartered Accountants of India regarding guidance
on implementation of amendments in tax audits
prescribed by CBDT from time to time.
31/08/18 Detailed representation submitted by the apex body
of Chartered Accountants viz. the Institute of
Chartered accountants of India (ICAI) before the
CBDT for extension of time line for submission of Tax
audit reports along with related returns from 30/09/18
to 31/10/18. Manifest grievances and concerns
faced by the professionals & tax payers were
highlighted, interalia, being the following:
a) Revision of Form 3CD (tax audit reports) mid way
is effectively a retrospective amendment as
against the declared resolve of the government;
b) Introduction of many new clauses in Revised
Form 3CD applicable w.e.f.20/08/18;
c) Sufficient time required to disseminate
understanding and to digest changes before
application;
d) Applicability of penal provisions u/s
271B(inadvertently stated as 271D) for delay in
submission of tax audit reports;
e) Issues arising due to implementation of GST law
for the first time & its impact on the computation
of income;
f) Extension of timeline of filing Return of Income in
case of certain category of taxpayers (being
essentially individuals drawing income from
salary or individuals not subject to tax audit) from
31/07/18 to 31/08/18, thus, there is all the more
reason for extending of time line in respect of
assessee's subject to tax audit required to file
return by 30/09/18;
g) Income tax department web site is not allowing to
upload certain forms related with Tax audits;
h) In view of manifest changes made there is an
acute burden on the CAs including tax
professionals;
i) Constant changes in utilities relating to tax audit
forms;
j) Heavy floods disrupting the normal life.
10/09/18 On not receiving any response from the Respondent
/ CBDT the ICAI files another detailed representation
outlining once again the various grievances and
concerns faced, interalia, on account of manifest mid
way amendments & changes in the Return utilities
including Tax audit report etc.
17/09/18 On not receiving any response from the Respondent
/ CBDT the ICAI files yet another detailed
representation outlining once again the various
grievances and concerns faced, interalia, on account
of manifest mid way amendments & changes in the
Return utilities including Tax audit report etc &
accordingly requesting to extend the prescribed time
line for filing return of income including tax audit from
30/09/18 to 31/10/18.
Various Similar representations filed by other professional
dates associations also outlining similar grievances &
requesting CBDT to extend the prescribed time line
for filing return of income including tax audit & related
forms from 30/09/18 to 31/10/18.
22/09/18 Petitioner / assessee files a detailed representation
before the Respondent / CBDT reiterating the
concerns expressed in the earlier representations
made by ICAI vide their three separate submissions
& accordingly requesting the CBDT to exercise the
powers as entrusted u/s 119 of the Act by extending
the due date of filing of Income tax return including
tax audit in case of all assessee's who are required
to furnish the same on or before 30/09/18 by at least
a month's time till 31/10/18.
A Single Judge Bench of this Court vide its decision
dated 21/09/15 in the case of Avinash Gupta Vs
UOI (2015) 378 ITR 137 (Del.) had importantly vide
para 22 of its decision held that there appears to be
no justification for delay beyond the assessment year
in prescribing the forms required for preparation of
returns including finalizing the tax audits. The
respondent / CBDT was accordingly directed by this
Hon'ble Court to, with effect from the next
assessment year, at least ensure that the forms, etc.,
which are to be prescribed for the audit report and for
filing the ITR are available as on 1st April of the
assessment year unless there is a valid reason there
for and which should be recorded in writing by the
respondents themselves, without waiting for any
representations to be made. This Hon'ble Court
further directed that the respondents, while doing so,
to also take a decision whether owing thereto any
extension of the due date is required to be prescribed
and accordingly notify the public.
That subsequently several Division Benches of
various High Courts have unanimously held that it is
the duty of CBDT to ensure that all the forms and
utilities required for filing of Return of Incomes
including tax audits are notified latest by the 1st day
of April of the assessment year.
Gujarat High Court vide its decision in the case of All
Gujarat Federation of Tax Consultants Vs CBDT
(2015) 378 ITR 160 (Guj.) held that the power under
section 119 of the Income-tax Act, 1961, is a
beneficial power given to the Central Board of Direct
Taxes for proper administration of fiscal law so that
undue hardship may not be caused to the assessees
and the fiscal laws may be correctly applied. For
filing the tax returns, appropriate utility is required to
be made available by the Central Board of Direct
Taxes to the assessees. Therefore, till such utility is
provided, it was not possible for the assessees to file
their returns. Therefore, as held by the Gujarat High
Court there is a duty cast upon the Central Board of
Direct Taxes to ensure that necessary utility for e-
filing of the returns is made available to various
categories of assessees at the beginning of the
assessment year so that the assessees can plan
their tax matters accordingly. The Gujarat High
Court accordingly in view of delay extended the due
date applicable for AY 2015-16 from 30th September
15 to 31 October 15. It is important to note that the
Gujarat High Court vide its clear direction directed
that henceforth the CBDT shall endeavor to ensure
that the forms and utilities required for e-filing of
returns are made available in the first day of April of
the assessment year.
To similar effect it has been so held in the decision of
Punjab & Haryana High Court in the case of Vishal
Garg & others Vs UOI 378 ITR 145 (P&H) & by the
Bombay High Court vide its decision in the case of
Chamber of Tax Consultants & others Vs UOI 378
ITR 188 (Bom.). Under similar circumstances the
Punjab & Haryana High Court & Bombay High Court
have directed for extension of date of filing return of
income including tax audit for AY 2015-16 from
30/09/15 to 31/10/15.
On the facts for present AY 2018-19, as on 31/07/18
app. 94% of the Returns are pending for filing as per
the estimate (Annexure P5) which in fact does not
considers the growth rate for present assessment
year. There is a 71% growth rate expected in the
current year as per the Press Information Bureau
report dated 01/09/18 (Annexure P6). It is a matter
of fact that a total of 100 changes have been made in
the tax audit reporting requirements during the
months of July September'18 (Annexure P7) being
an admitted fact by the Respondent itself as per
Annexure P8. Approximately 306 changes have
been made in the tax utility in the web site of tax
department since April'18 & substantially in the
months of July September '18 (Annexure P9).
Further for certain amendments made in tax audit
report (Form 3CD) no corresponding notification has
been prescribed as outlined in Annexure P15.
As per the snapshot from web site of tax department
itself (Annexure P14) more than 50% of Return filing
work is done outside office hours. This percentage is
bound to increase manifold times given the present
state of affairs.
Further the current year AY 2018-19 was also a year
of vibrancy in terms of GST implementation. The
inordinate delay in notification of reporting
requirements concerning GST & other things for
instance vide notification dated 20/07/18 of CBDT is
causing serious difficulty for tax payers &
professionals.
In the cumulative effect all of the aforesaid
circumstances particularly the 100 changes effected
in Tax audit reporting requirements utility / schema &
306 changes effected in the various ITR forms
utility/schema in the web site of tax department since
April'18 & substantially in the months of July
September '18 is placing not only the tax
professionals but also the various tax payers /
assessee's in a very difficult & perplexed situation
resulting in an environment of high uncertainty &
stress making it impossible to comply with the
requirement of filing the return of income including
tax audit report & related forms.
This situation has happened totally for reasons
beyond the control of tax payers / assessee's and as
a paradox the assessee's / tax payer's will be subject
to interest / penalty / disallowances etc on account of
non filing of return by 30/09/18,
Hence this Petition.
Dated : 24/09/18 Piyush Kaushik
Advocate
A-455, Sector 46
Noida - 201301
Tel: 09811310355; 0120-
2571160;61
IN THE HIGH COURT OF DELHI AT NEW DELHI
CIVIL WRIT JURISDICTION
WRIT PETITION (C) No. _____ OF 2018
IN THE MATTER OF:
Northern India CA Federation ...Petitioner
Vs.
Central Board of Direct Taxes ...Respondent
AND
IN THE MATTER OF:
CIVIL WRIT PETITION UNDER ARTICLES 226/227 OF THE
CONSTITUTION OF INDIA FOR ISSUANCE OF AN
APPROPRIATE WRIT, ORDER OR DIRECTION(S) ESPECIALLY
A WRIT IN THE NATURE OF MANDAMUS OR ANY OTHER
APPROPRIATE WRIT THEREBY DIRECTING THE
RESPONDENT TO EXTEND BY VIRTUE OF POWERS
BESTOWED U/S 119 OF INCOME TAX ACT, 1961, THE DUE
DATE FOR FILING OF INCOME TAX RETURN INCLUDING TAX
AUDIT REPORTS AND OTHER FORMS IN CASE OF
ASSESSEE'S REQUIRED TO FURNISH THE SAME ON OR
BEFORE 30/09/2018 BY AT LEAST A MONTHS FURTHER TIME
I.E. BY 31/10/2018 PURSUANT TO INNUMERABLE
DIFFICULTIES FACED BY TAX PAYERS / PROFESSIONALS AS
DETAILED IN VARIOUS REPRESENTATIONS BEFORE THE
RESPONDENT FROM TIME TO TIME PARTICULARLY &
INTERALIA BEING A SIGNIFICANTLY HIGH NUMBER OF
AMENDMENTS EFFCECTED BY THE RESPONDENT IN
REPORTING REQUIREMENTS & INCOME TAX UTILITY
MAINLY DURING THE MONTHS OF JULY-SEPTEMBER'18.
TO,
HON'BLE THE CHIEF JUSTICE AND HIS COMPANION
JUDGES OF THE HON'BLE HIGH COURT OF DELHI AT
NEW DELHI
MOST RESPECTFULLY SHOWETH:
1. That the Petitioner is filing the present Writ Petition under Articles
226/227 of the Constitution of India for issue of an appropriate
writ, order or directions especially a writ in the nature of
mandamus or any other appropriate writ thereby directing the
respondent to extend by virtue of powers bestowed u/s 119 of the
Income tax Act, 1961, the due date for filing of Income tax Return
including tax audit reports and other forms in case of assessee's
required to furnish the same on or before 30/09/2018 by at least
a months further time i.e. by 31/10/2018 pursuant to innumerable
difficulties faced by tax payers / professionals as detailed in
various representations before the respondent from time to time
particularly & interalia being a significantly high number of
amendments effected by respondent in reporting requirements &
Income tax utility particularly during the months of July-
September'18.
FACTS.
2. Petitioner is a Non Government Organization (NGO) registered
under the provisions of Societies Registration Act, 1860
established to promote and protect the interest of Chartered
Accountants (CA) amongst the CA fraternity of Northern India. It
aims at promoting the interest of CAs, interalia, by way of
conducting educational training programs; providing regular
updates in the matters of accounting, auditing, taxation etc.
Members of petitioner / assessee are professional Chartered
Accountants.
3. That on 01/10/2015 the Hon'ble Revenue secretary
acknowledging the concerns of Chartered Accountants of
inordinate delay on part of revenue in issuance of forms; utilities
etc required for preparation & filing of e-Returns of Income
including Tax audit reports issued a statement by way of twitter
that all the forms; etc required for preparation of return of
incomes including finalizing of tax audits will be notified well in
advance from forthcoming years. True copy of same is
enclosed as Annexure P1.
4. That on 31/03/2017 the Finance Bill 2017 applicable for
Financial Year 2017-18 (Assessment Year (AY) 2018-19)
passed by the Parliament.
5. As mandated by Hon'ble Division benches of various High
Courts (detailed infra) and as also accepted by the revenue, all
the final Forms, utilities, notifications etc required for preparation
& filing of Returns of Income for AY 2018-19 were to be notified
& finalized latest by 01/04/2018 date being the first date of AY
2018-19. However, nothing could be done till this date by the
Respondent.
6. That thereafter between 14/04/18- 21/05/18 only the first base
version utility uploaded in the web site of Income department
required for e-filing the Return of Incomes.
7. That thereafter on various dates from 20/04/18 19/09/18
innumerable changes made by the Income tax department in the
base utility version required for e-filing tax returns. A total of 306
changes (app.) made during this time as summarized in
Annexure P9.
8. That thereafter also on various dates 20/07/18; 01/08/18;
20/08/18; 01/09/18 & 07/09/18 innumerable changes made by
Income tax department in the Tax audit reporting requirements
i.e. Form No. 3CA & 3CD. Total of such changes made being
100 (app.) in No. as summarized in Annexure P7 being an
admitted position by the Income tax department itself vide its
Form 3CD-Schema Change Document dated 07/09/18
(Annexure P8).
9. That thereafter on 20/07/18 yet another notification prescribed
by CBDT in connection with tax audits required for filing return
by 30/09/18, true copy enclosed as Annexure P10.
10. That thereafter on 26/07/18 an order u/s 119 of Income tax Act,
1961 (`the Act') issued by CBDT extending the timeline of filing
Return of Income in case of certain category of taxpayers
(being essentially individuals drawing income from salary or
individuals not subject to tax audit) from 31/07/18 to 31/08/18.
True copy of same enclosed as Annexure P12.
11. That on 22/08/18 an implementation guide issued by the
Institute of Chartered Accountants of India regarding guidance
on implementation of amendments in tax audits prescribed by
CBDT from time to time, extracts from same enclosed as
Annexure P13
12. That on 31/08/18 a detailed representation was submitted by
the apex body of Chartered Accountants viz. the Institute of
Chartered accountants of India (ICAI) before the CBDT for
extension of time line for submission of Tax audit reports along
with related returns from 30/09/18 to 31/10/18. Manifest
grievances and concerns faced by the professionals & tax
payers were highlighted, interalia, being the following:
a. Revision of Form 3CD (tax audit reports) mid way is
effectively a retrospective amendment as against the
declared resolve of the government;
b. Introduction of many new clauses in Revised Form 3CD
applicable w.e.f.20/08/18;
c. Sufficient time required to disseminate understanding and to
digest changes before application;
d. Applicability of penal provisions u/s 271B(inadvertently
stated as 271D) for delay in submission of tax audit reports;
e. Issues arising due to implementation of GST law for the first
time & its impact on the computation of income;
f. Extension of timeline of filing Return of Income in case of
certain category of taxpayers (being essentially individuals
drawing income from salary or individuals not subject to tax
audit) from 31/07/18 to 31/08/18, thus, there is all the more
reason for extending of time line in respect of assessee's
subject to tax audit required to file return by 30/09/18;
g. Income tax department web site is not allowing to upload
certain forms related with Tax audits;
h. In view of manifest changes made there is an acute burden
on the CAs including tax professionals;
i. Constant changes in utilities relating to tax audit forms;
j. Heavy floods disrupting the normal life.
True copy of same enclosed as Annexure P2.
13. That on not receiving any response from the Respondent /
CBDT the ICAI files another detailed representation dated
10/09/18 outlining once again the various grievances and
concerns faced, interalia, on account of manifest mid way
amendments & changes in the Return utilities including Tax
audit report etc. True copy of same enclosed as Annexure P3.
14. That still on not receiving any response from the Respondent /
CBDT the ICAI files yet another detailed representation dated
17/09/18 outlining once again the various grievances and
concerns faced, interalia, on account of manifest mid way
amendments & changes in the Return utilities including Tax
audit report etc & accordingly requesting to extend the
prescribed time line for filing return of income including tax
audit from 30/09/18 to 31/10/18. True copy of same enclosed
as Annexure P4.
15. That similar representation were also filed by other professional
associations outlining similar grievances & requesting CBDT to
extend the prescribed time line for filing return of income
including tax audit & related forms from 30/09/18 to 31/10/18.
True copy of same enclosed as Annexure P17.
16. That thereafter on 22/09/18 petitioner / assessee files a
detailed representation before the Respondent / CBDT
reiterating the concerns expressed in the earlier
representations made by ICAI vide their three separate
submissions & accordingly requesting the CBDT to exercise
the powers as entrusted u/s 119 of the Act by extending the
due date of filing of Income tax return including tax audit in
case of all assessee's who are required to furnish the same on
or before 30/09/18 by at least a month's time till 31/10/18. True
copy of same enclosed as Annexure P16.
LEGAL POSITION.
17. U/s 119(2)(a) of the Act the CBDT may if it considers it
necessary or expedient so to do, for the purpose of proper and
efficient management of the work of assessment and collection
of revenue issue from time to time whether by way of relaxation
of any of the provisions, interalia, of section 139 of the Act
general or special orders in case of class of cases setting forth
directions or instructions not being prejudicial to assesses as to
the guidelines, principles or procedures to be followed by other
income-tax authorities in the work relating to assessment or
collection of revenue or the initiation of proceedings for the
imposition of penalties and any such order may, if the Board is
of opinion that it is necessary in the public interest so to do, be
published and circulated in the prescribed manner for general
information.
18. A Single Judge Bench of this Court vide its decision dated
21/09/15 in the case of Avinash Gupta Vs UOI (2015) 378 ITR
137 (Del.) had importantly vide para 22 of its decision held that
there appears to be no justification for delay beyond the
assessment year in prescribing the forms required for
preparation of returns including finalizing the tax audits. The
respondent / CBDT was accordingly directed by this Hon'ble
Court to, with effect from the next assessment year, at least
ensure that the forms, etc., which are to be prescribed for the
audit report and for filing the ITR are available as on 1st April of
the assessment year unless there is a valid reason there for and
which should be recorded in writing by the respondents
themselves, without waiting for any representations to be made.
This Hon'ble Court further directed that the respondents, while
doing so, to also take a decision whether owing thereto any
extension of the due date is required to be prescribed and
accordingly notify the public.
19. That subsequently several Division Benches of various High
Courts have unanimously held that it is the duty of CBDT to
ensure that all the forms and utilities required for filing of Return
of Incomes including tax audits are notified latest by the 1st day
of April of the assessment year.
20. Gujarat High Court vide its decision in the case of All Gujarat
Federation of Tax Consultants Vs CBDT (2015) 378 ITR 160
(Guj.) held that the power under section 119 of the Income-tax
Act, 1961, is a beneficial power given to the Central Board of
Direct Taxes for proper administration of fiscal law so that undue
hardship may not be caused to the assessees and the fiscal
laws may be correctly applied. For filing the tax returns,
appropriate utility is required to be made available by the Central
Board of Direct Taxes to the assessees. Therefore, till such
utility is provided, it was not possible for the assessees to file
their returns. Therefore, as held by the Gujarat High Court there
is a duty cast upon the Central Board of Direct Taxes to ensure
that necessary utility for e-filing of the returns is made available
to various categories of assessees at the beginning of the
assessment year so that the assessees can plan their tax
matters accordingly. The Gujarat High Court accordingly in view
of delay extended the due date applicable for AY 2015-16 from
30th September 15 to 31 October 15. It is important to note that
the Gujarat High Court vide its clear direction directed that
henceforth the CBDT shall endeavor to ensure that the forms
and utilities required for e-filing of returns are made available in
the first day of April of the assessment year.
21. To similar effect it has been so held in the decision of Punjab &
Haryana High Court in the case of Vishal Garg & others Vs
UOI 378 ITR 145 (P&H) & by the Bombay High Court vide its
decision in the case of Chamber of Tax Consultants & others
Vs UOI 378 ITR 188 (Bom.). Under similar circumstances the
Punjab & Haryana High Court & Bombay High Court have
directed for extension of date of filing return of income including
tax audit for AY 2015-16 from 30/09/15 to 31/10/15.
22. GROUNDS.
A. BECAUSE on the facts for present AY 2018-19, as on date
app. 94% of the Returns are pending for filing as per the
estimate (Annexure P5) which in fact does not even
considers the growth rate for present assessment year.
B. BECAUSE there is a 71% growth rate expected in the
current year as per the Press Information Bureau report
dated 01/09/18 (Annexure P6).
C. BECAUSE it is a matter of fact that a total of 100 changes
have been made in the tax audit utility / schema reporting
requirements during the months of July September'18
(Annexure P7) being an admitted fact by the Respondent
itself as per Annexure P8.
D. BECAUSE approximately 306 changes have been made in
the various ITR forms utility / schema in the web site of tax
department since April'18 & substantially in the months of
July September '18 (Annexure P9).
E. BECAUSE for certain amendments made in tax audit report
(Form 3CD) no corresponding notification has been
prescribed as outlined in Annexure P15.
F. BECAUSE per the snapshot from web site of tax department
itself (Annexure P14) more than 50% of Return filing work is
done outside office hours. This percentage is bound to
increase manifold times given the present state of affairs.
G. BECAUSE the current year AY 2018-19 was also a year of
vibrancy in terms of GST implementation. The inordinate
delay in notification of reporting requirements concerning
GST & other things for instance vide notification dated
20/07/18 of CBDT is causing serious difficulty for tax payers
& professionals.
H. Because the cumulative effect all of the aforesaid
circumstances particularly the 100 changes effected in Tax
audit utility/schema/ reporting requirements & 306 changes
effected in various ITR forms / utility/ schema in the web site
of tax department since April'18 & substantially in the months
of July September '18 is placing not only the tax
professionals but also the various tax payers / assessee's in
a very difficult & perplexed situation resulting in an
environment of high uncertainty & stress making it
impossible to comply with the requirement of filing the return
of income including tax audit report & related forms.
I. BECAUSE the aforesaid situation has happened totally for
reasons beyond the control of tax payers / assessee's /
Chartered Accountants including members of the petitioner
and as a paradox all of above parties will be subject to
interest / penalty / disallowances etc etc on account of non
filing of return by 30/09/18.
J. BECAUSE there is no alternative remedy available with the
Petitioner to challenge the impugned order except by way of
this Petition under Articles 226/227 of the Constitution of
India.
K. BECAUSE the balance of convenience is in favor of
Petitioner & against the Respondent.
23. That on the present subject matter the Petitioner has not filed
any similar writ petition before this Court or any other Court or
Supreme Court.
24. That all the annexures annexed to the writ petition are the true
copies of their respective originals.
PRAYER
In view of the facts and circumstances of the case and the
averments made above, the Petitioner respectfully prays that this
Hon'ble Court may graciously be pleased to:
i. Issue of an appropriate writ, order or directions especially a writ in
the nature of mandamus or any other appropriate writ thereby
directing the respondent to extend by virtue of powers bestowed
u/s 119 of the Income tax Act, 1961, the due date for filing of
Income tax Return including tax audit reports and other forms in
case of assessee's required to furnish the same on or before
30/09/2018 by at least a months further time i.e. by 31/10/2018
pursuant to innumerable difficulties faced by tax payers /
professionals as detailed in various representations before the
respondent from time to time particularly & interalia being a
significantly high number of amendments effected by respondent
in reporting requirements & Income tax utility particularly during the
months of July- September'18;
ii. Award cost of these proceedings to the Petitioner;
iii. Pass such further order(s) that this Hon'ble Court may deem fit in
the given facts and circumstances of the case.
PETITIONER
THROUGH
New Delhi : Piyush Kaushik
Advocate
Dated : A-455, Sector 46
Noida - 201301
Tel: 09811310355; 0120-
2571160;61
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