Meghalaya HC Allows Late Physical ITR Filing After Deadline

In a significant decision offering relief to taxpayers facing digital limitations, the Meghalaya High Court has permitted the filing of a physical Income Tax Return (ITR) even after the expiry of the revised return filing period. The Court directed the Centralized Processing Centre (CPC) Assessing Officer to accept the return in physical format from the assessee.

This ruling marks a notable exception in India's highly digitized income tax filing regime, acknowledging genuine errors and systemic limitations.

Case Background: Who Filed and Why?

The petitioner in the case was Shyam Century Ferrous Ltd., a company that had originally filed its ITR on 14 February 2022 for the assessment year 2021–22. The return disclosed an income of ₹1.68 crore and a tax liability of ₹43.78 lakh. However, the company erroneously failed to reduce a capital gain of ₹6.38 crore earned from investment sales — a figure already disclosed elsewhere in the return.

This omission led to an inflated income being taxed, despite the company's intent to disclose the gain correctly.

Efforts Made to Fix the Error

On discovering the error, the company:

1. Filed an application for rectification under Section 154 of the Income Tax Act.

2. When no action followed, it appealed under Section 246A — which was dismissed, as the mistake wasn't considered an “error apparent on record.”

3. Then approached the Income Tax Appellate Tribunal (ITAT) under Section 253. While ITAT allowed partial relief, it upheld the view that the correction needed to be made via a revised return or under Section 264.

The Catch: Time Limit Expired

Unfortunately, the deadline for filing a revised return for that assessment year had already passed. Since revised returns must be filed online, the company was stuck without a digital correction route.

Court’s Intervention: Physical Return Allowed

At this point, the company approached the Meghalaya High Court, seeking permission to submit a physical return.

• Appellant’s Argument: The company should be allowed to file a corrected ITR in physical form, given the genuine error and technical constraints.

• Tax Department’s Argument: Physical returns are not allowed since they cannot be processed by the CPC’s automated system.

However, the Court emphasized fairness and justice over technical rigidity, directing the CPC AO to accept the physical return, especially since the department itself had earlier permitted such filing in genuine cases.

Why This Ruling Matters

• Sets a precedent for similar cases where genuine mistakes can't be digitally corrected.

• Reinforces taxpayer rights in procedural roadblocks.

• Demonstrates judicial flexibility in navigating tax law technicalities.

Frequently Asked Questions (FAQs)

Q1. Can physical ITRs be filed after the deadline?
Generally no — but in exceptional cases like this, courts may allow it.

Q2. What is Section 154 of the Income Tax Act?
It allows for rectification of errors apparent from the record — not detailed or interpretative mistakes.

Q3. Why did the digital system not accept the correction?
Because the time limit to file a revised return online had lapsed.

Q4. Can other taxpayers rely on this order?
While this case sets a persuasive precedent, other taxpayers must approach courts individually based on merit.

Q5. What’s the takeaway for taxpayers?
Always review returns thoroughly before submission — but if a genuine error arises, legal remedy is possible.

Conclusion

The Meghalaya High Court’s decision shines a light on the importance of equity and fairness in tax proceedings. In an era of digitized tax compliance, this case highlights that the law still leaves room for genuine hardship to be addressed — even if it means returning briefly to paper.