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CA Final · Direct Tax Laws & International Taxation · Appeals and Revision

An order was communicated to Sharma Traders on 1 July 2026 and was in fact known to the assessee on 15 June 2026, when it saw the order on the portal. The assessee has waived its right of appeal. Within what time must it ordinarily file an application for revision under section 378(3) of the Income-tax Act, 2025, counted from which date?

The application must be made within one year from 15 June 2026. Section 378(3) counts the period from the date of communication or the date the assessee otherwise came to know of the order, whichever is earlier, and the portal knowledge on 15 June is earlier than the 1 July communication.

  1. AOne year from 1 July 2026, the date of communication.
  2. BOne year from 15 June 2026, the earlier date on which it came to know of the order.Correct
  3. CTwo years from 1 July 2026.
  4. DSixty days from 15 June 2026.

Explanation

Section 378(3) requires the application within one year from the date of communication or the date the assessee otherwise came to know of the order, whichever is earlier. 15 June 2026 is earlier than 1 July 2026, so the period runs from 15 June 2026. The first option wrongly uses the later date.

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