In the result, grounds of appeal raised by the assessee are allowed
Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay
139(1) is directory and not mandatory and, therefore, relief shall be granted by the appellate authority in case, there was genuine and valid reason for the delay in filing of return. 15. That there was genuine and valid reason for the delay in filing of return and moreover these provisions are directory and not mandatory. 16. That the claim