The Chief Commissioner has dismissed the compounding application of the petitioner on the  ground that the application was filed beyond the period of 36 months from the date of the complaint relying  upon paragraph 9.1 of CBDT guidelines dated 16 November 2022 . On writ allowing the petition the Court held that the competent authority has treated the guidelines as a binding statute and the competent authority had no jurisdiction to entertain a compounding application because it was made beyond 36 months. Court directed the Chief Commissioner to re consider the application as per the observation of the Supreme Court in Vinubhai Mohanlal Dobaria v .CCIT.(2025) 171 taxmann.com 268 ( SC) . Accordingly the writ petition is allowed . (WP (L) No. of 21032 of 2024 dt .4-3 -2025 )