Tata Project Provident Fund Trust Vs PCIT (Supreme Court of India)
Supreme Court of India dismissed the special leave petition filed against the judgment of the Telangana High Court, thereby affirming the High Court’s refusal to interfere with the rejection of a time-barred revision application under Section 264 of the Income-tax Act, 1961. While the delay in approaching the Supreme Court was condoned, the Court declined to interfere on merits and dismissed the petition, letting the High Court’s decision stand.
Read HC Judgment: IT Revision Application Rejected Due to 7 Year Delay Without Sufficient Cause
Before the Telangana High Court, the issue arose from a revision petition filed on 28.10.2024 against rejection of a rectification application dated 01.12.2016, relating to disallowance of exemption under Section 10(25) for Assessment Year 2014–15. The rectification rejection had been uploaded on the Income Tax portal on 01.12.2016. The revision was rejected by the Principal Commissioner of Income Tax on 01.08.2025 on the ground of inordinate delay of about 91 months, coupled with gross negligence and laches.
The petitioner Trust contended that it was unaware of the rectification rejection since the communication was sent to the email ID of a former employee and claimed that exemption under Section 10(25) had been allowed in earlier and subsequent years. It relied on judicial precedents to seek condonation of delay, arguing that the delay was neither deliberate nor contumacious.
