The Bombay High Court has asked the Central Board of Direct Taxes (CBDT) to extend the deadline for e-filing income tax returns for taxpayers who must file by December 31, 2024.
The court asked the CBDT extend the initial deadline till January 15, 2025, ensuring that all qualified taxpayers can claim the rebate under Section 87A of the Income Tax Act of 1961 without meeting procedural barriers.
The order was issued by a bench of Chief Justice DK Upadhyaya and Justice Amit Borkar while hearing a Public Interest Litigation (PIL) petition filed by The Chamber of Tax Consultants through its president, Vijay Bhatt, challenging the Income Tax Department’s modifications to the utility software used for filing returns for the assessment year (AY) 2024-25.

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Petitioner’s counsel, Percy Pardiwala and Dharan Gandhi, contended that the software update on July 5, 2024, unfairly prevented taxpayers from collecting the Section 87A rebate. This refund, designed for individual taxpayers with an income of up to Rs7 lakh, was dramatically increased from the previous ceiling of Rs5 lakh under the Finance Act of 2019.
The PIL said that the software upgrade violated statutory restrictions and undercut the legislative objective to provide tax relief to low- and middle-income people. It also stripped eligible taxpayers of their rights, causing confusion and undermining trust in tax administration.
IT attorneys Akhileshwar Sharma and Abhishek Mishra contended that the utility software meets regulatory standards and prevents errors.
However, the court questioned whether procedural changes to the program might supersede taxpayers’ substantive rights. It highlighted that the refund is inextricably related to overall income and tax due and should not be hampered by administrative inefficiencies.

Bombay High Court noted
The court noted that legal advantages must be applied in accordance with legislative goals. The judgment ordered the CBDT to publish a notification under Section 119 to extend the filing date, stating that procedural changes that deprive taxpayers of such benefits “require judicial intervention to rectify the anomaly and ensure justice.”
“Tax authorities should operate as facilitators, assisting taxpayers in complying with the law rather than creating obstructions through technical or administrative barriers. “Ensuring fairness, equity, and transparency in tax administration is critical for restoring public trust in the system,” the bench stressed.
It also proposed allowing taxpayers who did not claim the refund to file updated returns under Section 139(5) by December 31, 2024.
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