DINESH NAGINDAS SHAH Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) RULE . Mr. Manish R. Bhatt, learned standing counsel waives service of rule for the respondent. In the facts and circumstances of the case, the petition is taken up for final disposal today.

(2.) THESE two petitions are directed against two separate orders dt. 8th March, 2004 and 9th March, 2004, respectively, passed by the CIT, Ahmedabad, rejecting the two petitioners' revision petitions under Section 25 of the WT Act, 1957 (hereinafter referred to as 'the Act'), on the ground that the revision petitions were filed beyond the period of limitation.

(3.) THE CIT heard the learned counsel for the assessee and held that although the petition under Section 25 was required to be made within a period of one year, the petitioners had filed the revision petition beyond the period of limitation and that there was nothing to show that the assessee were prevented from making applications within the prescribed time. Ignorance of the petitioners and their chartered accountant cannot be a ground for condoning the delay; otherwise there will be no finality to the proceedings. The CIT, accordingly, rejected the application for condoning the delay in filing the revision petitions in respect of all the assessment years. That is the order under challenge in these petitions.