Revisional authority must decide Section 264 pleas on merits and issue a speaking order, not reject them as premature.

A revision petition under Section 264 of the Income-tax Act cannot be refused as premature merely because the Revenue may still be considering whether to appeal another decision. The revisional authority must examine the assessee's grievance on merits and pass a reasoned, speaking order, particularly where the request concerns an alleged excess tax deposit. Because the impugned order declined to address the controversy substantively and gave no meaningful reasoning, it was set aside and the matter was remanded for fresh decision after hearing the petitioner.

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Issues: Whether the revision petition under Section 264 of the Income-tax Act, 1961 could be declined as premature without a decision on merits, and whether the matter required remand for a reasoned order.

Analysis: The impugned order declined to entertain the revision petition on the ground that the Revenue still had time to decide whether to appeal against an ITAT decision, and therefore the legal position was not settled. The order did not address the controversy on merits and gave no substantive reasoning on the petitioner's claim for revision. A statutory revision petition under Section 264 required consideration of the merits of the assessee's grievance and a reasoned determination, especially when the petitioner had sought rectification of an alleged excess tax deposit.

Conclusion: The order was unsustainable and was set aside. The matter was remanded to the respondent for passing a reasoned order after granting an opportunity of hearing to the petitioner.

Ratio Decidendi: A revision petition cannot be rejected as premature merely because the Revenue may still consider an appeal against another decision; the revisional authority must apply its mind to the merits and pass a speaking order.

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