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

An order was passed against Mehta & Sons on 15 July 2026 and was communicated to the assessee on 20 July 2026. Mehta & Sons wants to apply for revision of that order under section 378 of the Income-tax Act, 2025, and no appeal is pending or available. Separately, the Commissioner is considering revising the same order on his own motion. Which statement is correct?

The Commissioner can revise suo motu up to 15 July 2027. Section 378(2) bars own-motion revision of an order made more than one year previously, and the period runs from the date of the order, not from its communication to the assessee.

  1. AThe Commissioner can revise suo motu up to 15 July 2027, since the order must not have been made more than one year previouslyCorrect
  2. BThe Commissioner can revise suo motu up to 20 July 2027, being one year from communication
  3. CThe Commissioner can revise suo motu at any time, because there is no time limit
  4. DThe Commissioner cannot revise suo motu, because revision is possible only on the assessee's application

Explanation

Section 378(2) bars suo motu revision if the order was made more than one year previously. Time runs from the date the order was made (15 July 2026), not from communication. The date of communication matters only for the assessee's application under section 378(3).

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