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Section 264 empowers Commissioner to revise assessment order to provide relief to assessee in cases of over-assessment, even if assessee did not file revised return. Commissioner erred in rejecting revision application merely on ground that assessee did not file revised return. Section 264 is a salutary provision to remedy bona fide mistakes and correct inadvertent situations in assessment proceedings to prevent injustice. Goetze and M.S. Raju decisions not applicable in present case. Commissioner directed to pass appropriate order u/s 264 on merits of adjustment claimed by assessee.
Section 264 empowers Commissioner to revise assessment order to provide relief to assessee in cases of over-assessment, even if assessee did not file revised return. Commissioner erred in rejecting revision application merely on ground that assessee did not file revised return. Section 264 is a salutary provision to remedy bona fide mistakes and correct inadvertent situations in assessment proceedings to prevent injustice. Goetze and M.S. Raju decisions not applicable in present case. Commissioner directed to pass appropriate order u/s 264 on merits of adjustment claimed by assessee.
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