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

Meera Textiles Ltd received an assessment order from the Assessing Officer on 10 June 2026, which was communicated to it on the same day. The company has not filed any appeal and the time to appeal has not yet expired. It files an application for revision before the Principal Commissioner under section 378 of the Income-tax Act, 2025. What is the position?

The Principal Commissioner cannot revise the order. Under section 378(5)(a), revision is barred where an appeal lies but has not been made and the time for appeal has not expired. The one-year period for the application does not remove this bar.

  1. AThe Principal Commissioner can revise the order, since the application is within one year
  2. BThe Principal Commissioner cannot revise the order, because an appeal lies against it, has not been made, and the time to appeal has not expiredCorrect
  3. CThe Principal Commissioner can revise the order only if the company pays a fee of Rs. 1,000
  4. DThe Principal Commissioner can revise the order only if the company first files an appeal to the Appellate Tribunal

Explanation

Section 378(5)(a) bars revision where an appeal lies to the Commissioner (Appeals) or the Tribunal but has not been made and the appeal period has not expired. The one-year application window does not override this bar. The option allowing revision on the basis of the one-year window ignores the bar, so it is wrong.

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