Relief u/s 89

I think  there is no such condition. In earlier years he may not have taxable income so he is not liable to file return. But now he may liable because of his increased income. So he can claim 89 relief

i remember 1 clause was there, if TDS done by employer (i think CG employees) need not file ITR upto 5 lakhs gross income. I have filed for many people 89 relief and received refund also. remember to file 10E online