Commissioner can condone delay in Section 264 applications without relying on Limitation Act Section 5.

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....Applications u/s 264 for revision in favor of assessee - Condonation of delay - Proviso to Sub-Section (3) of Section 264 confers a statutory power on the Commissioner to condone the delay. Therefore it was not necessary for the Commissioner to have taken recourse to Section 5 of the Limitation Act, 1963. - HC....