Tata Project Provident Fund Trust Vs PCIT (Telangana High Court)
Telangana High Court examined a writ petition challenging the rejection of a revision application filed under Section 264 of the Income-tax Act, 1961, seeking revision of an order rejecting rectification related to disallowance of exemption under Section 10(25) for Assessment Year 2014–15. The rectification request had been rejected on 01.12.2016, while the revision petition was filed on 28.10.2024, resulting in a delay of about 91 months. The Principal Commissioner of Income Tax rejected the revision on 01.08.2025, holding that the delay was inordinate and that no sufficient cause was shown for condonation under Section 264(3).
Read SC Judgment: SC Upholds Rejection of Time-Barred Income Tax Revision for Lack of Sufficient Cause
The petitioner Trust, which manages provident fund contributions and is registered under the Employees’ Provident Funds and Miscellaneous Provisions Act, 1952, contended that it was unaware of the rectification rejection as the communication had been sent to the email ID of a former employee. It was argued that the delay was not deliberate, that exemption under Section 10(25) had been allowed in earlier and subsequent years, and that a later assessment order for Assessment Year 2022–23 had accepted the exemption. Reliance was placed on judicial precedents to argue for liberal condonation of delay.
