Remedy U/s. 264 could not be treated as regular remedy by passing regular remedy of appeals

Nataraju (HUF) Vs PCIT (Karnataka High Court)

the fact that the assessees-petitioners preferred these Revision petitions under section 264 of the Act just before the expiry of one year of the impugned assessment orders passed by the Assessing Authority, on the contrary reflects that the petitioners-assessees were very conscious and aware of the legal provision and deliberately avoided the availing of the regular remedy by way of an appeal and at the nick time of the expiry of the time period, preferred the present revision petition under section 264 of the Act, which for good reaso

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