Revisional Powers Under Section 264 Cannot Be Limited to Correcting Mistakes in Assessment Orders

The HC quashed and set aside an order passed under s.264 of the Income Tax Act, remanding the matter for fresh determination. The Court held that notice under s.148 was never served upon the petitioner's late husband, preventing the Assessing Officer from validly assuming jurisdiction. The Court found that the Commissioner had incorrectly limited the scope of revisional powers under s.264 to mere correction of mistakes in the assessment order. The HC clarified that s.264 confers wide powers on the Commissioner to consider the entire assessment proceedings, conduct inquiries, and pass appropriate non-prejudicial orders. The Commissioner's truncated interpretation of s.264 was deemed contrary to the statutory provision itself. .....

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