S. 279 : Offences and prosecutions – Sanction – Chief Commissioner – Commissioner – Application for compounding of offence – Rejected on the ground of limitation and the fact that assessee was already convicted by Magistrate – Conviction order set aside by CBI Judge and directed a fresh trial – High Court sets aside rejection of compounding application as (i) CBDT Circular had relaxed time limit to file a such application and (ii) second objection no longer survives as the conviction set aside – Revenue to consider the application seeking compounding on its own merit and in accordance with law [ S. 119 , 276CC, 278E, Art , 226 , CRPC , 391 ]