For the assessment year 2014-15, the Assessing Officer passed an order under section 143(3) against the assessee. Thereafter, the assessee filed an application before the Principal Commissioner under section 264 in which it submitted that it had commenced its business operations during the previous year 2013-14 and accordingly the assessment year 2014-15 was the first year under assessment and that though it was entitled to claim deduction under section 80-IA because of a bona fide error it did not claim it either at the time of filing the return of income or during the assessment proceeding. The assessee also sought condonation of delay of 52 days. The Principal Commissioner condoned the delay and observed that the assessee did not opt to make the claim to deduction under section 80-IA and that in the subsequent assessment year 2015-16 also, the assessee did not make such claim before the Assessing Officer. He opined that the assessee chose not to claim deduction under section 80-IA and declined to interfere under section 264 in the order of the Assessing Officer. On a writ  allowing the petition, that there was no limitation on the exercise of power under section 264 by the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner. The order rejecting the assessee’s application was set aside. The matter was remanded to the Principal Commissioner for reconsideration of the revision application filed by the assessee under section 264 on the merits after giving due opportunity of hearing to both the sides. Relied on   Geekay Security Services (P) Ltd. v. DY. CIT [2019] 101 taxmann.com 192 (Bom)(HC), Gooetze (India) Ltd v.CIT (2006) 284 ITR 323 (SC) distinguished.(AY.2014-15)