Pursuant to sanction of the scheme of arrangement the transferee company attempted to file revised returns without filing an application for condonation of the delay in filing them on the basis that the sanctioned scheme of arrangement and, in particular, clause 64(c) thereof, entitled such filing and was binding on the Income-tax authorities. This contention was accepted by a single judge under article 226 of the Constitution. On appeal, the Court held that the Department had been notified that the scheme of arrangement enabled the amalgamated company and transferee company to file returns and revised returns before the tax authorities, including the Income-tax authority. However, it could not be said that the Department had consented to waive the procedures or statutory requirements prescribed in the Income-tax Act for this purpose. In this regard, the order of the Company Law Tribunal whereby the scheme of arrangement was sanctioned also mandated that necessary permissions should be obtained and compliances fulfilled. The transferee company was required to comply with the procedure for filing a revised return belatedly. (AY. 2015-16, 2016-17)