# Supreme Court: I-T revision plea cannot bypass return deadline

2026-08-09T15:51:00+00:00 | Governance | Indian Opinion Desk

Corroboration: 1 independent outlet

The Supreme Court has ruled that a revision petition under Section 264 of the Income Tax Act cannot be used to revise a self-assessment return after the statutory deadline has passed. A bench of Justices J B Pardiwala and K Vinod Chandran set aside a Bombay High Court order that had remanded the matter for fresh consideration. The case involved M/s Om Siddhakala Associates, which filed a self-assessment return that led to a tax demand. The firm did not file a revised return within the allowed time but instead challenged the demand under Section 264. The Principal Commissioner rejected the plea, and the Supreme Court upheld that view, saying using Section 264 to revise a return after the deadline is an impermissible backdoor move. The court declined to rule on whether the tolerance limit under Section 43CA is retrospective.

## Coverage

- deccanherald.com <https://www.deccanherald.com/india/cant-use-i-t-revision-plea-to-bypass-deadline-for-revising-returns-supreme-court-4105033>

Tags: dispute resolution, Income Tax Act, Karnataka, Section 264, Supreme Court, tax returns
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