https://www.taxtmi.com/caselaws?id=796892 Section 264 provides wide, beneficial revisional jurisdiction to relieve an assessee from over-assessment, including where the excess tax results from the assessee's own mistake or failure to claim relief in the return. Expiry of the period for filing a revised return under Section 139(5) does not bar revision where the same income has been taxed in two assessment years. Treating a disallowance in one year and its reversal in another as separate events cannot justify double taxation. Retention of tax not lawfully due contravenes Article 265. The Commissioner must examine reconciliations and the double-taxation claim on merits rather than mechanically reject revision by applying standards associated with Section 263. en-us Mon, 20 Jul 2026 00:00:00 +0530 Wed, 12 Aug 2026 08:20:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796892 Section 264 provides wide, beneficial revisional jurisdiction to relieve an assessee from over-assessment, including where the excess tax results from the assessee's own mistake or failure to claim relief in the return. Expiry of the period for filing a revised return under Section 139(5) does not bar revision where the same income has been taxed in two assessment years. Treating a disallowance in one year and its reversal in another as separate events cannot justify double taxation. Retention of tax not lawfully due contravenes Article 265. The Commissioner must examine reconciliations and the double-taxation claim on merits rather than mechanically reject revision by applying standards associated with Section 263. Case-Laws Income Tax Mon, 20 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796892