Suo Moto Disallowance Made By Assessee Under Bonafide Belief Of Tax Liability Can Be Rectified U/S 264 Of Income Tax Act Without Amending ITR: Delhi HC

The Delhi High Court ruled that an assessee’s bonafide belief of tax liability, which led to self-disallowance under the Income Tax Act, can be rectified under Section 264, without amending the Income Tax Return (ITR). The case concerned an individual who had disallowed certain expenses under the assumption that they were taxable, but later realized they were not. The court held that the rectification process could proceed based on the assessee’s original belief, ensuring that tax-related errors could be corrected without formal amendments to the return.