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of The HC rejected the revision petition under section 264, noting the petitioner failed to file a reply or submit documentary evidence before the AO. The petitioner's non-participation was attributed to a change in management and notices being served under the old PAN, causing lack of awareness. The Court held that non-participation alone does not bar prosecution under section 264. Given the petitioner's society converted from a Trust to a Society, resulting in management difficulties, the HC exercised discretion in the interest of justice. The impugned order under section 264 and the best judgment assessment order under section 147 were set aside. The matter was remanded to the AO for fresh consideration, thereby granting the petitioner an opportunity to present the case afresh.
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