Law does Not Require Performance of Impossible Act: ITAT directs Revenue to adopt Constructive Approach in ITR-7 Filing [Read Order]

The ITAT ruled that the law cannot mandate the performance of impossible acts, directing revenue authorities to take a constructive approach in cases like ITR-7 filing. The taxpayer in this case faced technical challenges that rendered compliance impossible within the stipulated timeline. The tribunal emphasized the importance of procedural fairness and flexibility, particularly when delays occur due to circumstances beyond the taxpayer’s control. Legal experts view this ruling as a precedent for addressing compliance challenges arising from systemic or technical issues. Taxpayers are advised to document such difficulties thoroughly to seek relief in similar situations. This decision reinforces the judiciary’s commitment to balancing procedural obligations with practical challenges faced by taxpayers, ensuring equity and justice in tax administration.