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

Nair Exports Pvt. Ltd. received an order on 5 March 2026 (communicated on 8 March 2026), and it learnt of the order informally on 1 March 2026. It files an application for revision under section 378 of the Income-tax Act, 2025. Within what period must the application be made, counted from when?

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

  1. AOne year from 8 March 2026, the date of communication, because it is the later date
  2. BOne year from 1 March 2026, the date on which it otherwise came to know, because it is the earlier dateCorrect
  3. CSixty days from 8 March 2026
  4. DThirty days from 1 March 2026

Explanation

Section 378(3) requires the application within one year from the date the order was communicated or the date on which the assessee otherwise came to know of it, whichever is earlier. The earlier date here is 1 March 2026. The later date (8 March) is the wrong base, and the 60-day and 30-day periods do not apply.

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