Prospective effect of CBDT circular

The Kerala High Court set aside an order rejecting an assessee's application for condonation of delay in filing an income tax return for Assessment Year 2018-19. 

The Court held that the Principal Commissioner had failed to consider the prejudice caused by the introduction of CBDT Circular No. 11/2024, which reduced the condonable period from six years to five years. 

Without expressing any final view on the merits, the Court directed fresh consideration of the assessee's application in light of the legitimate expectation created under the earlier circular.