[2025:RJ-JP:13838-DB] HIGH COURT OF JUDICATURE FOR RAJASTHAN BENCH AT JAIPUR D.B. Civil Writ Petition No. 973/2004 M/s Shree Shakuntala Industries, Head Office Old Industrial Area, Alwar through its Partner Shri Ajay Agarwal s/o Shri Inder Mal Gupta, aged 40 years, R/o 172, Arya Nagar, Alwar. ----Petitioner Versus 1. Union of India, through Chief Commissioner Income Tax, Statue Circle, Jaipur. 2. Commissioner of Income Tax, Alwar 301001. ----Respondent For Petitioner(s) : Mr. Anant Kasliwal, Sr. Advcoate assisted by Ms. Charu Pareek Ms. Divisha Mishra For Respondent(s) : Mr. Anuroop Singhi with Mr. Aditya Khandelwal HON'BLE MR. JUSTICE AVNEESH JHINGAN HON'BLE MR. JUSTICE MANEESH SHARMA Order 26/03/2025 The challenge to the present petition is to the order of the Commissioner Income Tax dated 09.12.2003 passed under Section 264 of the Income Tax Act, 1961 refusing to exercise power on the rectification application filed beyond the period of four years. The total effect involved in this petition is less than Rs.30,000/-. Considering the paltry amount involved in the petition, no case is made out for interference in its jurisdiction. The petition is dismissed. However, it is clarified that substantial question of law involved in this petition are kept open. (MANEESH SHARMA),J (AVNEESH JHINGAN),J Deepa/1