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CS Executive · Tax Laws and Practice · Procedural Compliance under Income Tax

Under section 239(3)(c) of the Income-tax Act, 2025, the Board may relax a requirement for claiming a deduction under Chapter IV or VIII where there is genuine hardship. Which pair of conditions must both be satisfied?

Both conditions must be met: the default must have arisen from circumstances beyond the assessee's control, and the assessee must have complied with the requirement before the assessment for the relevant tax year was completed. Other conditions suggested, such as extra tax payment, are not required.

  1. ADefault was due to circumstances beyond the assessee's control, and the requirement was complied with before completion of assessment for that tax yearCorrect
  2. BDefault was due to circumstances beyond the assessee's control, and the requirement was complied with before the end of the next tax year
  3. CThe assessee has paid additional tax on the claim, and the requirement was complied with before completion of assessment
  4. DThe Assessing Officer has recorded satisfaction, and the requirement was complied with before the due date of filing the return

Explanation

Section 239(3)(c) requires (i) that the default was due to circumstances beyond the assessee's control and (ii) that the assessee complied with the requirement before completion of assessment for the tax year of the claim. The 'next tax year', 'additional tax' and 'return due date' conditions are not in the provision.

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