2009 (12) TMI 25

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....ged the order dated 3.1.2007 passed by the Commissioner under Section 264 of the Income Tax Act, 1961. The facts in narrow compass are that on 13.10.2006, the Assessing Officer has passed the assessment order under Section 143(3) of the Income Tax Act. The assessee has filed a revision under Section 264 of the Income Tax Act on 22.11.2006 after depositing the requisite fee. The Commissioner ....

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....d for Rs. 2,00000/-. So, Rs. 2,00000/- were accepted and properly explained in the income, as such the addition of remaining amount of Rs. 2,00000/- was sustained by the Commissioner. Thus, the Commissioner has sustained the addition of Rs. 70,000/- plus Rs. 2,00000/- is equal to Rs. 2,70,000/-. Not being satisfied, the petitioner has filed the present petition. Heard Sri R.A.Shankhdhar, learne....

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....own in the case of Punjab Feed Mills v. I.T.O., 1997(94 Tax ----- 405) P & H. but High Court will not ordinarily interfere with the order passed by the Commissioner under Section 264 as per the ratio laid down in the case of S.A.Wahab v. ITO & another, 232 ITR 624 where it was observed that "the order passed under Section 264 provides substantial relief to the assessee not carrying any miscarri....