Aadhaar and Income-Tax Returns: Legal Notes by Arvind Datar
It is, therefore, suggested that persons who do not have Aadhaar should adopt the following steps:
The income-tax returns should be filled up manually;
The return should be filed before the Jurisdictional Assessing Officer with a covering letter stating that they have chosen not to enroll for Aadhaar and that the return cannot be uploaded electronically without Aadhaar number. Consequently, they have no option but to file it manually; and
Such manual filing has been permitted by the Gujarat and Kerala High Courts.
It is also hoped that the CBDT issues a circular that enables the filing of manual returns till the Aadhaar judgment is pronounced.