https://www.taxtmi.com/caselaws?id=759436 The HC held that the Commissioner erred in rejecting the revision application under s 264 solely because the petitioner did not file a revised return. Section 264 empowers the Commissioner to correct over-assessment or bona fide mistakes even after assessment completion, not limited to errors by lower authorities. The court emphasized that s 264 serves to prevent injustice from inadvertent errors by the assessee. Prior decisions cited by the respondent were found inapplicable as they involved different factual and legal contexts. The HC allowed the petition, restored the revision proceedings to the Commissioner, and directed appropriate orders to be passed under s 264 considering the merits of the petitioner's claim. en-us Mon, 23 Sep 2024 00:00:00 +0530 Mon, 04 Aug 2025 18:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=759436 The HC held that the Commissioner erred in rejecting the revision application under s 264 solely because the petitioner did not file a revised return. Section 264 empowers the Commissioner to correct over-assessment or bona fide mistakes even after assessment completion, not limited to errors by lower authorities. The court emphasized that s 264 serves to prevent injustice from inadvertent errors by the assessee. Prior decisions cited by the respondent were found inapplicable as they involved different factual and legal contexts. The HC allowed the petition, restored the revision proceedings to the Commissioner, and directed appropriate orders to be passed under s 264 considering the merits of the petitioner's claim. Case-Laws Income Tax Mon, 23 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=759436