Kamal Pasricha As Trustee of Kuldip Kaur Trust v. ITO [2025] 171 taxmann.com 620 /[2026] 491 ITR 176 (Bom) (HC)

S. 264: Commissioner-Revision of other orders-Intimation under section 143(1)-Intimation is an order-Alternate remedy-Commissioner cannot refuse jurisdiction.[S. 143(1), Art. 226]

Where the Commissioner declined to exercise revisional jurisdiction under section 264 on the ground that the assessee had an alternate remedy of filing an appeal against an intimation issued under section 143(1), the High Court held that there was no limitation under section 264 enabling the Commissioner to refuse to exercise revisional jurisdiction on such ground and, accordingly, the impugned order was set aside. (AY. 2014-15).

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