Assessee-company entered into a scheme of arrangement transferring business with Hind Lamps Limited.  Approved scheme mandated revised returns of income, tax filings, and accounting adjustments for tax purposes to reflect demerger’s effects. Due to COVID-19 lockdowns, preparation of special purpose financial statements and tax audit reports was delayed and assessee manually filed revised income tax returns for assessment years 2014-15 to 2021-22-Assistant Commissioner however, vide order dated 3-6-2022, rejected manual processing of revised returns.  He relied on section 119(2)(b) read with Circular No. 9 of 2015, dated 9-6-2015 to state that assessee could file its application before respective authority in granting relief. On writ the Court held that  in view of decision of Supreme Court in Dalmia Power Ltd. v. Asstt. CIT [2019] 112 taxmann.com 252/[2020] 26 Taxman 352/420 ITR 339, provision of section 139(5) would not be applicable in a case where revised return could not be filed on account of time taken to grant sanction of Schemes of Arrangement and Amalgamation by NCLT. The  Asstt. Commissioner also accepted applicability of said decision but maintained their binding adherence to CBDT Circular, in said circumstances, impugned order dated 3-6-2022 was set aside and revenue authorities were directed to accept and process assessee’s manual revised return of income for assessment years 2014-15 to 2021-22.  Section 170A was applicable only from assessment year 2022-23 onwards, while assessee’s case pertained to assessment years 2014-15 to 2021-22 hence, reliance on new provision and circular would not be applicable in case of assessee.  Circular No. 9 of 2015, dated 9th June 2015 and CBDT Circular 19th September 2022. (AY. 2014-15 to 2021-22)