For assessment year 2014-15, the assessee-trust, registered under the Employees’ Provident Funds and Miscellaneous Provisions Act, 1952, was denied exemption under section 10(25) while processing the return, and its rectification application was rejected on 01.12.2016 and uploaded on the income-tax portal. After nearly seven years, the assessee filed a revision under section 264 with a condonation application, contending that it was unaware of the rejection as the communication had gone to a former employee’s e-mail identity, and that the exemption had been allowed in earlier and later years. The Court held that the assessee, being an institutional assessee, was expected to exercise reasonable diligence; the order having been uploaded on the portal and the demand being visible, no sufficient cause was shown for the delay of about ninety-one months, and allowability in other years was irrelevant. The findings of the Principal Commissioner warranted no interference. (AY. 2014-15)