https://www.taxtmi.com/caselaws?id=448640 The Bombay HC held that the Commissioner should have condoned the delay in filing revision under Section 264 of the Income Tax Act, adopting a liberal approach to advance substantial justice. The court emphasized that Section 264 powers are wide and enable relief in cases of over-assessment. Regarding the petitioner's undisclosed income declared under IDS scheme, since tax, surcharge, penalty and interest were paid, the amount cannot be included in taxable income per Section 188. The HC directed the Commissioner to consider the Section 264 application on merits and pass orders in accordance with law. en-us Wed, 17 Jan 2024 00:00:00 +0530 Fri, 12 Jul 2024 12:51:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=448640 The Bombay HC held that the Commissioner should have condoned the delay in filing revision under Section 264 of the Income Tax Act, adopting a liberal approach to advance substantial justice. The court emphasized that Section 264 powers are wide and enable relief in cases of over-assessment. Regarding the petitioner's undisclosed income declared under IDS scheme, since tax, surcharge, penalty and interest were paid, the amount cannot be included in taxable income per Section 188. The HC directed the Commissioner to consider the Section 264 application on merits and pass orders in accordance with law. Case-Laws Income Tax Wed, 17 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=448640