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The HC held that the revisional authority under Section 264 is competent to rectify bona fide errors committed by the assessee in the return, even after the time for filing a revised return has expired. The impugned order was quashed for erroneously refusing to permit reliance on disclosures related to the profit and loss account on the ground that only the assessee can alter the return particulars. The Court emphasized that jurisdiction under Section 264 extends to correcting mistakes by the assessee and remanded the matter for fresh consideration in accordance with this principle. The prior refusal to exercise jurisdiction was held to be an error warranting interference.
The HC held that the revisional authority under Section 264 is competent to rectify bona fide errors committed by the assessee in the return, even after the time for filing a revised return has expired. The impugned order was quashed for erroneously refusing to permit reliance on disclosures related to the profit and loss account on the ground that only the assessee can alter the return particulars. The Court emphasized that jurisdiction under Section 264 extends to correcting mistakes by the assessee and remanded the matter for fresh consideration in accordance with this principle. The prior refusal to exercise jurisdiction was held to be an error warranting interference.
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