https://www.taxtmi.com/caselaws?id=754278 Kerala HC dismissed the writ appeal challenging CIT's rejection of revision application under section 264 for delay. The assessee had declared share sale profits as capital gains in 2004-05 and 2005-06 but revenue later treated similar income as business income in 2006-07 and 2008-09. The assessee delayed filing revision petitions until after appellate authority confirmed the changed treatment. HC held that condoning delay would give unfair advantage to assessee while revenue was similarly barred by limitation from reassessing earlier years. The delay could not be condoned. en-us Fri, 14 Jun 2024 00:00:00 +0530 Thu, 20 Jun 2024 15:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=754278 Kerala HC dismissed the writ appeal challenging CIT's rejection of revision application under section 264 for delay. The assessee had declared share sale profits as capital gains in 2004-05 and 2005-06 but revenue later treated similar income as business income in 2006-07 and 2008-09. The assessee delayed filing revision petitions until after appellate authority confirmed the changed treatment. HC held that condoning delay would give unfair advantage to assessee while revenue was similarly barred by limitation from reassessing earlier years. The delay could not be condoned. Case-Laws Income Tax Fri, 14 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=754278