2024 (10) TMI 179

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....MAR RAMAMOORTHY For the Petitioner: Mr.S.Sathyanarayanan For the Respondents: Mrs.S.Premalatha, Junior Standing Counsel ORDER An order dated 14.03.2024 rejecting the revision petition under Section 264 of the Income Tax Act, 1961 (the Income Tax Act) is challenged in this writ petition. 2. The petitioner had filed the return of income for assessment year 2020-2021 on 31.12.2020. In ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....od for filing the revision petition is one year. Therefore, he submits that the revision petition was filed well within the period of limitation. By referring to paragraph 7 of the impugned order, learned counsel contends that the revision petition was rejected on a hyper technical ground that the petitioner did not show sufficient cause for not participating in the assessment proceedings. He subm....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... 5. As per sub-section (3) of Section 264, a revision application is required to be made within one year from the date on which the relevant order was communicated to the revision applicant. In this case, the assessment order is dated 23.09.2022 and the revision application was filed on 26.12.2022. Hence, the petition was filed well within the period of limitation. Once a petition is filed withi....