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TMI BlogRejection of revision application u/s 264 in favor of assessee: A beneficial provision of Income Tax Act.X X X X Extracts X X X X X X X X Extracts X X X X ..... 03.2022, in which its application for revision under Section 264 of the Income Tax Act, 1961 , was rejected. The petitioner is engaged in the IT and IT-enabled services business. Income Tax Return : The petitioner filed its return of income for the assessment year 2018-2019 on 29.11.2018, admitting a total income of Rs. 12,65,47,680/-. During that financial year, the petitioner declar ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ime limit for filing a revised return had expired when the petitioner realized it could have availed the benefit under Section 90 of the Income Tax Act . Additionally, it was argued that Section 248 of the Income Tax Act is inapplicable to a case where DDT was computed at a higher rate. Court's Decision : The court found that the rejection was not based on the merits of the ap ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Taxation Avoidance Agreement, and the rejection of the revision application based on available remedies. The implication is that the petitioner will have another opportunity to have its case reconsidered by the Principal Commissioner of Income Tax, and the impact would depend on the outcome of that reconsideration. Full Text : 2024 (1) TMI 614 - MADRAS HIGH COURT - FAQ - Frequen ..... X X X X Extracts X X X X X X X X Extracts X X X X
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