Order u/s 264 Must Be Issued Within a Year; Extension Beyond March 31, 2022, Not Allowed.

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....Revision u/s 264 - Period of limitation - an order under Section 264 is required to be passed within a period of one year from the end of Financial Year, in which, the application is made by the petitioner for revision. In the instant case, last date of passing of order was 31.03.2022. That being the position, the question of giving a direction to the Commissioner for passing of an order under Section 264 of the I.T. Act beyond the said period would not arise. Hence, we are of the view that such a request cannot be granted. - HC....