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

Kiran Pharma's revision application under the revision provisions was filed in FY 2026-27, so the normal deadline for the order is 31 March 2028. The High Court granted a stay on the proceedings from 1 January 2028 until the certified copy of the vacating order was received by the Principal Commissioner on 10 March 2028. Ignoring any rehearing period, by when does the Income-tax Act, 2025 as given require the order to be passed?

The order must be passed by 9 May 2028. The stay period is excluded, leaving only about 21 days after the vacating order is received on 10 March 2028. Because that is less than sixty days, the remaining time is extended to sixty days, ending 9 May 2028.

  1. A31 March 2028, since a stay does not affect the limit
  2. B29 April 2028
  3. C9 May 2028Correct
  4. D10 March 2028

Explanation

The stay period from 1 January to 10 March 2028 is excluded. Without the exclusion, only 21 days (10 March to 31 March 2028) would remain. Since less than sixty days would remain, the remaining period is extended to sixty days. Sixty days from 10 March 2028 gives 9 May 2028 (21 days in March, 30 in April, 9 in May). The date 29 April 2028 results from counting 50 days instead of 60.

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