Judgment ( 1. ) THE sole question for consideration is the date of starting of limitation for filing revision under Sub-section (3) of Section 264 of the Income Tax Act (for short "the Act" ). ( 2. ) THE fact is not in dispute that notices (R-1), (R-2) and (R-3) for depositing amount pursuant to assessment were served on the petitioner on 30th January, 1992. However, the assessment orders were not sent along with the notices. Assessment orders were passed on 13-1-1992. ( 3. ) THE petitioner applied for obtaining certified copies of the assessment orders on 8-12-1993 as per application (P-4 ). The certified copies were supplied to the petitioner on 6-1-1997; revision was preferred before the Commissioner of Income Tax, Bhopal on 24-11-97. The revision has been dismissed as barred by limitation by the Commissioner of Income Tax, Bhopal as per order (P-7), dated 23-2-1998. ( 4. ) LEARNED Counsel for petitioner submits that order impugned is bad in law; he places reliance on a circular issued by Central Board of Direct Taxes No. 10-D (C. No. 9 (22)-IT/47), dated 15th April, 1948. As per the circular the assessment order should be supplied to the assessee along with the demand notice. Learned Counsel submits that the actual knowledge of the assessment order could not be gathered by the petitioner from the notices (R-1), (R-2) and (R-3) served on the petitioner on 30th January, 1992. For the failure of Department to supply the assessment order as per circular, the revision filed by the petitioner ought to have been treated within the limitation and could not be dismissed. The order (P-7) is bad in law and learned Commissioner has failed to appreciate the provisions of Sub-section (3) of Section 264 of the Act read with the circular. ( 5. ) SHRI Rohit Arya, learned Standing Counsel for the Department submitted that the order is proper; the provisions of Section 264 (3) clearly prescribes the limitation either from thedate of service of the assessment order or the date on which the assessee otherwise came to know of it whichever is earlier. Thus, the limitation has to commence with effect from the service of the notices (R-1), (R-2) and (R-3) on 30-14992. Thus, the limitation has to commence with effect from the service of the notices (R-1), (R-2) and (R-3) on 30-14992. Precisely the submission of learned Counsel is that the petitioner came to know of the passing of the assessment orders as per notices (R-1), (R-2) and (R-3) issued to the petitioner and received by the petitioner on 30-1-1992. ( 6. ) THE sole question for consideration is the date of starting of limitation in the instant case and dependent upon that is the validity of the order (P-7) passed by the learned Commissioner of Income Tax. ( 7. ) SUB-SECTION (3) of Section 264 of the Act is relevant provision; the same is quoted below :-- "264 (3 ). In the case of an application for revision under this section by the assessee, the application must be made within one year from the date on which the order in question was communicated to him or the date on which he otherwise came to know of it, whichever is earlier : Provided that the Commissioner may, if he is satisfied that the assessee was prevented by sufficient cause from making the application within that period, admit an application made after the expiry of that period. " ( 8. ) A bare reading of aforesaid provision makes it clear that limitation for filing revision under Section 264 is of one year from the date on which the order in question was communicated to the assessee or the date on which the assessee otherwise came to know of it. ( 9. ) NEXT question for consideration is whether by the notices (R-1), (R-2) and (R-3) the assessee came to know of passing of assessment orders. ( 10. ) A bare perusal of the notices (R-1), (R-2) and (R-3) indicate that petitioner was given the information of the passing of the assessment order for the relevant years 1987-88,1988-89 and 1989-90. It is mentioned in the notice (R-1) that :-- "this is to give you notice that for assessment year 87-88 a sum of Rs. 79,544/- details of which are given on reverse has been determined to be payable by you. " ( 11. ) SAID intimation was given to the petitioner. It is mentioned in the notice (R-1) that :-- "this is to give you notice that for assessment year 87-88 a sum of Rs. 79,544/- details of which are given on reverse has been determined to be payable by you. " ( 11. ) SAID intimation was given to the petitioner. Similar mention is in R-1 and R-3 for assessment years 1988-89 and 1989-90 that assessment has been completed under Income Tax Act, 1961 and demand was raised of amount determined on the basis of assessment orders. Service of these demand notices (R-1) to (R-3) is not in dispute that they were served on 30-1-1992. There is receipt of endorsement on the notices (R-1), (R-2) and (R-3) of 30-1-1992. Thus, it is clear that petitioner had the knowledge and petitioner without even service of the assessment orders came to know of passing of the assessment orders. Thus, he clearly came to know otherwise of factum of passing of assessment order which is mode as contemplated to set in motion limitation of one year prescribed under Sub-section (3) of Section 264 of the Act. Petitioner applied for certified copy highly belatedly after service of demand notices, which were served on 30-1-92; petitioner applied in December, 93 when the period of limitation was already over and again after filing the application in December, 1993 obtained the certified copy only in 1997 after 3 years. It is clear that petitioner failed to pursue the case seriously. As per provision of Sub-section (3) of Section 264 of the Act no case is set out to the effect that petitioner after knowledge as per notices (R-1) to (R-3) was prevented by any cause much less sufficient cause from filing revision within one year w. e. f. 30-1-92. Having failed to avail the benefit of proviso, having come to know of the assessment order on 30-1-92, in my opinion, it is a case of callous negligence of the petitioner; conduct goes to show that the petitioner himself was responsible for belated filing of the revision after five years of having intimation of the passing of the assessment orders. Thus, in my opinion, the order (P-7) dismissing revision on the ground of limitation is in accordance with law and calls for no interference. ( 12. ) PETITION is without merit and is dismissed. Costs on parties. Security, if deposited, be refunded to the petitioner.