Assessee, a subsidiary of a Singapore based company faced a delay in filing its income tax return due to a disagreement between auditors in India and Singapore.It eventually filed its return on 14-5-2018. Prosecution was initiated based on a complaint dated 3-1-2019, leading to summons being issued on 9-11-2021. On 19-5-2022, after receiving summons, assessee filed a compounding application which was rejected on grounds of exceeding time limit specified in guidelines issued by Central Board of Direct Taxes on 14-6-2019. Which was rejected. On writ the Court held that neither sub-section (2) nor any of other sub-sections of section 279 prescribe a period of limitation with regard to compounding of offences. Even otherwise complaint was lodged on 3-1-2019 a period of about fifteen months lapsed between date of complaint and onset of Covid-19 pandemic and if period excluded under orders of Supreme Court, i.e. period running from 15-3-2020 to 28-2-2022, was excluded compounding application filed on 19-5-2022 would be within period prescribed in guidelines of Central Board of Direct Taxes. Order rejecting the application is quashed and compounding application of assessee was directed to be considered and disposed of on merits.  CBDT guidelines dated 14-6-2019