Sanjib Banerjee, J. - (1.) The petitioners challenge an order of March 18, 2015 passed by the Commissioner of Income Tax under Sec. 264 of the Income Tax Act, 1961. A copy of the revision application appears as Annexure P -2 to the petition.
(2.) In the returns filed for the assessment year 2009 -10, the petitioning assessee did not claim any deduction on account of bill discounting charges of Rs. 9,12,040/ - since the assessee reckoned that such deduction ought to be claimed in the subsequent assessment year. However, when the assessee claimed a deduction on account of the bill discounting charges for the financial year 2010 -11, the same was disallowed on the ground that the transaction pertained to the previous assessment year and the deduction ought to have been claimed then. The petitioners submit that the deduction was permissible some time or the other and there can be no dispute in such regard; they maintain that the only disagreement is as to whether the deduction should have been claimed for the assessment year 2009 -10 or the subsequent assessment year.
(3.) The petitioners explain that it was in such circumstances that the petitioning assessee sought a revision of the assessment order pertaining to assessment year 2009 -10, but such revision was carried to the Commissioner on June 20, 2013, about three months after the assessment order under Sec. 143(1) of the Act was passed on March 13, 2013 in respect of assessment year 2010 -11. The assessment order for assessment year 2009 -10 was passed on September 18, 2010.;