THE HON’BLE THE CHIEF JUSTICE SRI APARESH KUMAR SINGH AND THE HON’BLE SRI JUSTICE G.M.MOHIUDDIN

ORDER:

Heard Sri Percy J. Pardiwala, learned Senior Counsel representing Sri K. Pratik Reddy, learned counsel for petitioner, Smt. Bokaro Sapna Reddy, learned Senior Standing Counsel for Income-tax appearing for respondent Nos.1, 2 and 4 and Sri N. Bhujanga Rao, learned Senior Panel Counsel for Central Government appearing for respondent No.5.

2. Revision under Section 264 of the Income-tax Act, 1961 (for short ‘the Act’), is to be filed within a period of one year from the date on which the order in question i.e., the order passed on the petitioner’s application for rectification was rejected. The order of rejection is dated 01.12.2016. The revision application has been filed on 28.10.2024 before the Principal Commissioner of Income Tax-I, Hyderabad (PCIT). The same has been rejected by the impugned order dated 01.08.2025 on grounds of inordinate delay of 91 months, gross negligence and laches. The petitioner Trust manages the provident fund contributions of its employees and it is registered under the Employees’ Provident Funds and Miscellaneous Provisions Act, 1952. In respect of the r