https://www.taxtmi.com/caselaws?id=253634 The court held that the Commissioner should have considered whether the petitioner was subjected to double taxation and should have conducted an inquiry into the factual claims rather than focusing solely on the procedural aspect of the revised return's timeliness. The court quashed the order and remanded the case for fresh consideration, directing the Commissioner to pass orders on merits after affording the petitioner a personal hearing. The court emphasized the need for substantive inquiry under Section 264's wide powers and left open the issue of approaching the Board under Section 119(2). en-us Wed, 12 Nov 2014 00:00:00 +0530 Fri, 28 Nov 2014 12:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=253634 The court held that the Commissioner should have considered whether the petitioner was subjected to double taxation and should have conducted an inquiry into the factual claims rather than focusing solely on the procedural aspect of the revised return's timeliness. The court quashed the order and remanded the case for fresh consideration, directing the Commissioner to pass orders on merits after affording the petitioner a personal hearing. The court emphasized the need for substantive inquiry under Section 264's wide powers and left open the issue of approaching the Board under Section 119(2). Case-Laws Income Tax Wed, 12 Nov 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=253634