S. 264: Powers & duties of CIT while dealing with a revision application

Paradigm Geophysical Pty Ltd Vs. DCIT (Delhi High Court) The Commissioner’s reasoning and observation was that the petitioner, for some unexplained reasons, deliberately did not file an appeal against the assessment order for Assessment Year 2012-13, though it had filed appeals for other years. He held that this was an attempt to invoke Section 264 of the Act as a backdoor entry to file an appeal. Hence, the Revision petition should be dismissed. Held by Hon’ble High Court  Having heard the counsels for the petitioner and respondents, we find that the impugned reasoning cannot be ...