JUDGMENT : Debangsu Basak, J. Affidavit filed in Court be taken on record. 2. An order dated December 21, 2016 passed by the revisional authority is under challenge in the present writ petition. 3. Learned senior advocate appearing for the petitioners submits that, the impugned order suffers from view of breach of principles of natural justice. According to him, the High Court, while remanding the revisional petition for decision to the revisional authority by the order dated September 8, 2016, it required the revisional authority to afford a reasonable opportunity of hearing to the petitioners. The notice issued by the authorities subsequent to such order, said that, personal appearance was not necessary. The impugned order records that, none was present on behalf of the petitioners. According to him, such a stand taken by the authorities is contrary to the express direction contained in the order dated September 8, 2015 and, therefore, the impugned order stands vitiated. 4. On the merits of the matter, he submits that, the petitioners filed an application under Section 264 of the Income Tax Act 1961 raising primarily two issues. The petitioners wanted interest to be paid under Section 244(1)(A) of the Income Tax Act, 1961 and not under Section 244A(1)(b) of the Act of 1961 under which, interest was allowed by the Assessing Officer. Moreover, the petitioners wanted interest on delayed payment of interest which the Assessing Officer did not allow. According to him, none of the two issues have been decided upon by the impugned order. 5. Learned senior advocate appearing for the respondents submits that, the impugned order is detailed and contains reasons. The authorities proceeded on the basis of the order of the High Court. The petitioners did not appear before the revisional authority and, therefore, cannot make out a case of breach of principles of natural justice. Moreover, since the impugned order is detailed, no interference is called for. 6. It appears from the records made available to the Court that, the petitioners filed an application under Section 264 of the Act of 1961, being aggrieved by an order of assessment of the Assessing Officer dated May 6, 2004 in respect of assessment year 1983-1984 dealing with the issue to refund. The petitioners primarily canvassed two points before the revisional authority. The petitioners primarily canvassed two points before the revisional authority. One of the points is that, the petitioners are entitled to interest under Section 244(1)(A) of the Act of 1961 rather than Section 244A(1)(b) of the Act of 1961 as allowed. The other point is that, the petitioners are entitled to interest on delayed payment of interest. Such revisional application was disposed of initially by an order dated March 31, 2006. Such revisional order was challenged by the writ petitioners in a writ petition being W.P. No.1148 of 2006. The impugned order dated March 31, 2006 passed by the revisional authority was set aside by the order dated December 8, 2016. The following directions were issued :- "It appears from the order impugned passed by the Commissioner under Section 264 of the Income tax Act, 1961 dated March 31, 2006 that the merits of the claim have not been pronounced upon. It would be appropriate to request the Commissioner of Income-tax to consider the revision petition under Section 264 of the Income-tax Act, 1961 filed by the petitioner in accordance with law. The points raised by the parties are kept open. Needless to say, the Commissioner will pass a reasoned order after affording reasonable opportunity of hearing to the parties and will communicate such reasoned order to the parties forthwith thereafter. It is expected that the Commissioner will complete the entire exercise within twelve weeks from the date of communication of this order." 7. Subsequent to the order dated September 8, 2016, the revisional authority issued a letter dated September 28, 2016 fixing October 13, 2016 as the date of hearing. Such writing said that, the personal appearance was not necessary. There are correspondence between the petitioners and the revisional authority on the issue of hearing. Ultimately, the petitioners did not insist upon a personal hearing being granted. It required the revisional authority to dispose of the matter expeditiously in terms of the order of the High Court. 8. By the impugned order dated December 21, 2016, the revisional authority noticed that, nobody attended on behalf of the assessee. It proceeds to find the revisional application as barred by limitation without any prayer for condonation being made. It then purports to deal with the merits of the case by relying upon a judgment of the Supreme Court reported in 2013 (358) I.T.R. 291 . It proceeds to find the revisional application as barred by limitation without any prayer for condonation being made. It then purports to deal with the merits of the case by relying upon a judgment of the Supreme Court reported in 2013 (358) I.T.R. 291 . It however, does not allude to the applicability of either of the sections noted in the order of the Assessing Officer or in the petition for revision. It does not speak as to whether Section 244(1A) of the Act of 1961 will apply so far as calculation of interest for refund is concerned or provisions of Section 244(1)(b) of the Act of 1961 will apply as allowed by the Assessing Officer or not. It also does not deal with the issue raised in the revisional petition with regard to claim on account of delayed payment of interest. 9. So far as breach of principles of natural justice is concerned, I am not minded to be in favour of the petitioners. Although, the order of the High Court required the revisional authority to afford a reasonable opportunity of hearing, the revisional authority, by its writing dated August 28, 2016 informed the petitioners that, the personal appearance was not necessary. The petitioners accepted such position and did not insist upon a personal appearance. Therefore, it does not lie in the mouth of the petitioners to contend that, having disallowed personal appearance, the revisional authority ought not to have returned the findings as noted in paragraph 5 of the impugned order. 10. So far as the merits of the claim are concerned, it appears from the records that, the revisional authority did not dismiss the revisional application on the ground of limitation at the initial stage. Thereafter, by the order dated September 8, 2016, the revisional authority was requested to dispose of the revisional application by keeping all points open. In the impugned order, the revisional authority returns a finding that, the revisional application is barred by limitation. In the facts of the present case, it would not be in the interest of justice to dismiss the revisional application merely on the ground of limitation alone. The petitioners are diligently canvassing their points before different forai. The petitioners should not be held to be negligent in pursuing their remedies. Therefore, delay, if any, in filing the revisional application stands condoned. 11. The petitioners are diligently canvassing their points before different forai. The petitioners should not be held to be negligent in pursuing their remedies. Therefore, delay, if any, in filing the revisional application stands condoned. 11. The revisional authority did not deal with the two issues raised in the revisional application. It will proceed to do so. It will decide on the two issues raised in the revisional application in accordance with law, after affording a reasonable opportunity of hearing to the petitioners. It is open to the petitioners to waive their right of personal hearing, if they are so advised. The impugned order dated December 21, 2016 is quashed. The matter is remanded to the revisional authority for fresh consideration in light of the observations made herein. 12. W.P. No.25585(W) of 2017 is disposed of. 13. No order as to costs. 14. Urgent certified website copies of this order, if applied for, be made available to the parties upon compliance of the requisite formalities.