https://www.taxtmi.com/caselaws?id=23826 The High Court dismissed Bremco Corporation's petition seeking to quash the Commissioner of Income-tax's order rejecting their application under section 264 of the Income-tax Act. The court emphasized the discretionary nature of the Commissioner's power in granting relief under section 264 and found that the petitioner failed to establish entitlement to the claimed deduction. Judicial review under Article 226 focused on the decision-making process, ultimately concluding that the Commissioner's rejection was not arbitrary. The judgment highlights the importance of legal substantiation for claims and the need for the Commissioner to exercise discretion in accordance with legal principles. en-us Thu, 10 Aug 1989 00:00:00 +0530 Thu, 14 Jan 2010 15:17:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=23826 The High Court dismissed Bremco Corporation's petition seeking to quash the Commissioner of Income-tax's order rejecting their application under section 264 of the Income-tax Act. The court emphasized the discretionary nature of the Commissioner's power in granting relief under section 264 and found that the petitioner failed to establish entitlement to the claimed deduction. Judicial review under Article 226 focused on the decision-making process, ultimately concluding that the Commissioner's rejection was not arbitrary. The judgment highlights the importance of legal substantiation for claims and the need for the Commissioner to exercise discretion in accordance with legal principles. Case-Laws Income Tax Thu, 10 Aug 1989 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=23826