Income Tax: Section 143(1) intimation cannot be revised under Section 264

Murari Lal Narang Vs PCIT (Delhi High Court)

The Delhi High Court’s decision in the case of Murari Lal Narang vs. PCIT addresses a critical question: can an intimation under Section 143(1) of the Income-tax Act, 1961, be revised under Section 264 of the same Act? This case arose when the petitioner sought to claim an exemption for interest on enhanced compensation received for land acquisition, which had not been claimed in the original tax return. The Principal Commissioner of Income Tax (PCIT) rejected the revision application, prompting a deeper legal examination by the court.

Background

Murari Lal Narang, the writ petitioner, received enhanced compensation for land acquisition and sought to claim an exemption for the interest received under Section 10(37) of the Income-tax Act, 1961. This claim was not made in the original tax return. The petitioner filed a revision application under Section 264 of the Act, aiming to revise the intimation issued under Section 143(1).

PCIT’s Decision

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