Assessee filed return of income belatedly.  After 16 years it filed an application with CBDT for condonation of delay in filing return. CBDT rejected application. On writ the Court held that  since application for condonation of delay itself had been filed belatedly, CBDT had rightly rejected application. Court also observed that even a declaration of loss would require assessment so that only the genuine loss is recognised and which would be available for carry forward to be set off against future income or to claim refund. Accepting assessee’s request for such a huge delay would amount to reopening the assessment of assessment year 1998-99 in assessment year 2023-24. Referred.  CBDT Circular No. 9/2015, dated 9-6-2015. (2015)  374 ITR  25 (St).  (AY. 1998-99)