Direct Tax

Sec. 260A – Limitations – Where there was delay of 86 days in preferring appeal before High Court by revenue, High Court ought to have condoned delay and ought not to have been too technical in dismissing appeals on ground of delay.

Principal Commissioner of Income-tax v. Suncity Projects (P.) Ltd. – [2022] 145 taxmann.com 458 (SC).

Sec. 264 – Where assessee filed revision petition u/s 264 against an assessment order instead of statutory appeal, assessee should not be left remediless and should not be non-suited even to avail revisional remedy if he had chosen not to avail statutory appeal, thus revision petition ought to be heard and disposed off on merits.

Vikas Nigelia v. Commissioner of Income-tax – [2022] 145 taxmann.com 317 (Calcutta).