On same set of facts and same situation, there cannot be a differential treatment

Sahebsingh Bindrasingh Senagar (HUF) V. CCIT (Gujarat High Court)

In the present case, we have noted that in case of Karta of HUF in his individual capacity under identical circumstances, application for condonation of delay based on identical grounds came to be accepted by the Revenue. In same set of facts and same situation, there cannot be a differential treatment. Merely because one application was decided by the Commissioner and another by the Chief Commissioner cannot be a point of distinction.