Condonation of delay in tax revision refused where explanation was vague and no sufficient cause was shown

Refusal to condone a 1,460-day delay in filing a revision application under section 264 was treated as a plausible view and not interfered with in writ jurisdiction because the explanation for delay was vague and the assessee's continued statutory compliance showed no sufficient cause for late filing. The writ court declined to disturb that discretionary refusal under Article 226. Any observations on the merits were directed to be ignored and not treated as precedent.

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Issues: Whether the refusal to condone a delay of 1460 days in filing the revision application under section 264 could be interfered with in writ jurisdiction.

Analysis: The revision application was filed far beyond the statutory period under section 264(3) of the Income-tax Act, 1961, and the explanation offered for the delay was found to be vague. The assessee continued to comply with statutory obligations during the relevant period, including filing returns and completing audit requirements, which supported the conclusion that there was no sufficient cause preventing timely filing. The decision not to condone delay was therefore treated as a plausible view, warranting no interference under Article 226 of the Constitution of India. The observations on merits were directed to be ignored and not treated as precedent.

Conclusion: The refusal to condone delay was upheld and the writ petition failed.

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