Section 264 of Income Tax Act, 1961—In the instant case, petitioner is aggrieved against the order of CIT wherein CIT(A) has rejected the application filed by the petitioner u/s 264, on the ground that the same was filed beyond the time stipulated u/s 264.

Held that— this Court is of the view that ends of justice would be met if the matter is remitted back to the first respondent for reconsidering the matter afresh if the petitioner is in a position to satisfy the first respondent that the delay in filing such application under section 264 was neither willful or intentional.[M/S. AADIL ASHFAQUE & CO. PVT. LTD. VERSUS PRINCIPAL COMMISSIONER OF INCOME TAX, DEPUTY COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE-I (1) , CHENNAI.] [2019] 17 ITCD Online (44) [MADRAS HIGH COURT]