2018 (5) TMI 1734

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....Mauna M Bhatt(174) ORAL ORDER (PER : HONOURABLE MR.JUSTICE AKIL KURESHI) 1. Petitioner has challenged an order dated 26.03.2018 passed by the Principal Commissioner of Income Tax, rejecting the petitioner's Revision Petition filed under section 264 of the Income Tax Act, 1961 ('the Act' for short) on the ground that there was no explanation of delay for filing such petition. ....

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....e power of the revisional authority to condone delay on sufficient grounds being made out, the Revision Petition came to be dismissed by the Principal Commissioner by the impugned order on the ground that delay of nine days was not explained. He recorded that the assessee has not given any reason, let alone 'sufficient' reason for such delay. 5. Section 264 of the Act concerns the revis....

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....pplication within the period prescribed, admit the application even after expiry of such period. 6. Subsection (3) of section 264 of the Act thus while prescribing period of limitation, gives ample power to the Commissioner to accept an application filed beyond such period on sufficient grounds being made out. 7. In the present case, delay was extremely small. It is true that the petitioner ....