When an assessee included exempt income in her return as taxable income and the inaccuracy could not be rectified by filing a revised return because the original return was filed late, the assessee’s only recourse was to file a revision application under section 264. The Commissioner could not have rejected the revision application just because of the fact that the assessee failed to file a revised return. – Assistant Commissioner of Income-tax v. Ena Chaudhuri (Calcutta) [2023]