1995 (1) TMI 13

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..... April 27, 1994, passed by the Commissioner of Income-tax, Delhi-III, New Delhi, under section 264 of the Income-tax Act, 1961 (for short, "the Act"). In fact, the application of the petitioner under section 264 of the Act had been dismissed on the ground that there was delay in filing the application which delay had not been properly explained. Under section 264 of the Act, the Commissioner may .....

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..... eceived the assessment orders. It was, however, pointed out by Mr. B. Gupta, learned counsel for the Revenue, that the assessee is not only having the services of a chartered accountant but also of a tax consultant who was a former Indian Revenue Service person working in the Income-tax Department. The plea, therefore, that the petitioner could not get proper legal guidance cannot be held to be va .....

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