Section 264 Revision Cannot Be Denied on Technicalities for Elderly Alzheimer’s Patient

Shushilaben Jayantibhai Patel Vs PCIT (Gujarat High Court)

The petitioner, an 82-year-old senior citizen, approached the High Court challenging two orders: one passed under section 264 of the Income Tax Act by the Commissioner, and another passed under section 144 by the Assessing Officer for Assessment Year 2017-18. She also challenged the consequential demand notice issued under section 156. As the matter involved a short issue, the Court proceeded with final hearing.

The petitioner’s counsel argued that the Commissioner failed to exercise the wide discretionary powers a

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