Petitioner-transferee company merged transferor company with itself as per approved scheme of amalgamation by NCLT.  While revising accounts, etc., post-amalgamation, due date for filing revised return of income had expired, therefore, petitioner filed manual revised return relying upon Supreme Court decision in Dalmia Power Ltd. v. Asstt. CIT (2019) 112 taxmann.com 252/(2020) 269 Taxman 352/420 ITR 339 (SC).   However, Department did not accept such return on ground of absence of condonation of delay order of competent authority. On writ the Court held that  revised return could not be filed before due date by petitioner since circumstances were beyond control of petitioner, therefore, impugned order is   set aside and department is  directed to take into account revised return of income filed. Court also held that the provisions of section 170A, as inserted by Finance Act, 2022, would not apply for assessment year 2021-22, but for and from assessment year 2022-23   (AY. 2021-22)