Section 264 Revision Accepted: Suo Moto Disallowance Rectified

SMEC India (P.) Ltd. Vs PCIT (Delhi High Court) Delhi High Court held that suo moto disallowance with bona fide yet mistaken belief that amount is liable to be offered for taxation, such mistake can be rectified via revision application under section 264 of the Income Tax Act. Facts- The writ petitioner impugns the order passed by the Principal Commissioner dated 25 March 2019 and in terms of which it has proceeded to dismiss an application that had been instituted by the petitioner purporting to be u/s. 264 of the Income Tax Act, 1961. The dispute itself arose in the context of an amount of I...