Where assessee-firm’s application under section 264 claimed that section 115JC could not be applied to its housing project, which was approved and completed prior to 1-4-2013, on the basis of the jurisdictional Tribunal decision in S.K. Ventures v. ITO, [IT Appeal No.1248 (Mum) 2018, dated 5-3-2019  and Revenue rejected the application merely on the ground that the said decision was not acceptable to it, the High Court held that Revenue could not disregard a judicial precedent merely because it had been challenged before a superior Court; since the facts were identical, the ratio of S.K. Ventures was required to be followed and the matter was remanded for fresh consideration. (AY. 2020-21)