Just a moment...
Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
Press 'Enter' to add multiple search terms. Rules for Better Search
Use comma for multiple locations.
---------------- For section wise search only -----------------
Accuracy Level ~ 90%
Press 'Enter' after typing page number.
Press 'Enter' after typing page number.
No Folders have been created
Are you sure you want to delete "My most important" ?
NOTE:
Press 'Enter' after typing page number.
Press 'Enter' after typing page number.
Don't have an account? Register Here
Press 'Enter' after typing page number.
Issues: Whether the revision application under Section 264 of the Income-tax Act, 1961 was filed within limitation and, if so, whether it had to be considered and disposed of on merits.
Analysis: The revision application was filed within one year from the date of the assessment order communicated to the applicant. Once the application was within limitation, the revisional authority was required to examine the request on merits and exercise the wide revisional power conferred by Section 264 of the Income-tax Act, 1961. Rejection of the revision without such consideration was not in accordance with law.
Conclusion: The revision application was within limitation and was required to be decided on merits. The impugned order was liable to be set aside and the matter remanded for reconsideration.