Revision u/s. 264 — Scope of Power of Commissioner — Mistake in the return of income — Detected when intimation u/s. 143(1) issued/received — Time limit to file revised return expired — Powers of the Commissioner wide enough to rectify a bonafide mistake committed by the assessee even after the expiry of the time limit to file revised return.

33. 2025 (7) TMI 1439 (Cal.):

Crown Electromechanical Pvt Ltd. vs. Pr.CIT:

A.Y.: 2022-23: Date of order 15/07/2025:

Ss. 264 of ITA 1961

Revision u/s. 264 — Scope of Power of Commissioner — Mistake in the return of income — Detected when intimation u/s. 143(1) issued/received — Time limit to file revised return expired — Powers of the Commissioner wide enough to rectify a bonafide mistake committed by the assessee even after the expiry of the time limit to file revised return.

The Assessee filed its return of income for A. Y. 2022-23 declaring total income at ₹ 9,54,872. However, due to oversight certain figures which were required to be provided in the profit and loss account under Part – A of the return were not included. Subsequently, the return was processed and intimation u/s. 143(1) of the Income-tax Act, 1961 was issued wherein the total income was determined at ₹3,58,76,000 and a demand of ₹1,02,60,400 was determined to be payable by the assessee. It is only when the intimation u/s. 143(1) was issued that the assessee detected the mistake in the return of income filed by the assessee.

By the time the assessee received