JUDGMENT

Manmohan, J. (Oral). - C.M.No.8883/2022

Exemption allowed, subject to all just exceptions.

Accordingly, the application stands disposed of.

W.P.(C) 3071/2022

1. Present writ petition has been filed challenging the order dated 27th March, 2021 passed by Commissioner of Income Tax (International Taxation) -2 ['CIT(IT)'] , New Delhi for the Assessment Year 2018-19. Petitioner also seeks a direction to the Respondent to consider the Revision Petition filed on behalf of the Petitioner under Section 264 Income Tax Act, 1961 ('the Act') on merits after condoning the delay in preferring the petition.

2. Learned counsel for the petitioner states that vide impugned order the Revision petition filed by the Petitioner under Section 264 of the Act was arbitrarily dismissed on the ground of limitation. He states that the Petitioner under the bona fide mistake of law and relying on previous orders passed by ITO and CIT(A) in favour of the Petitioner on the same issue, filed an appeal under Section 248 of the Act on 10th April, 2018 under the belief that the said order is appealable. He states that the Petitioner meticulously pursued the said appeal until June, 2019.

3. Learned Counsel for the