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

An order was passed by the Assessing Officer on 1 August 2026 and communicated to Rohan Pvt Ltd on 5 August 2026. The company came to know of the order on 2 August 2026 through a portal alert. Under section 378(3) of the Income-tax Act, 2025, from which date does the one-year period for filing an application for revision begin?

The period begins on 2 August 2026. Section 378(3) counts one year from the earlier of the date of communication and the date the assessee otherwise came to know of the order. The knowledge date of 2 August is earlier than the communication date of 5 August.

  1. A1 August 2026, the date of the order
  2. B2 August 2026, the date the assessee otherwise came to know of it, being earlier than communicationCorrect
  3. C5 August 2026, the date of communication
  4. DThe later of 2 August and 5 August 2026

Explanation

Section 378(3) requires the application within one year from the date the order was communicated or the date the assessee otherwise came to know of it, whichever is earlier. The earlier date is 2 August 2026. Counting from the communication date of 5 August is wrong because it is the later date.

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