Skip to content

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

Rao Textiles Ltd. received an assessment order on 10 June 2026 from its Assessing Officer. The company has neither filed an appeal against it nor waived its right of appeal, and the period for filing the appeal has not yet expired. It now applies to the Principal Commissioner for revision of that order under the general revision provision (section 378 of the Income-tax Act, 2025). What is the position?

The Principal Commissioner cannot revise the order. Section 378(5)(a) bars revision where an appeal lies to the appellate authority but has not been filed and the appeal period has not expired. The one-year application period does not override that bar.

  1. AThe Principal Commissioner can revise the order, because the application was made within one year
  2. BThe Principal Commissioner cannot revise the order, because an appeal lies against it, has not been made and the appeal period has not expiredCorrect
  3. CThe Principal Commissioner can revise the order only if the fee of Rs. 500 is doubled
  4. DThe Principal Commissioner can revise the order, but only to the assessee's prejudice

Explanation

Under section 378(5)(a), the Competent Authority shall not revise an order where an appeal lies to the CIT(A) or the Tribunal but has not been made and the time for appeal has not expired. Rao Textiles' application is therefore not maintainable. The one-year window for applying does not override this bar, and revision cannot in any case be prejudicial to the assessee.

Did you get it right without looking?

One question tells you little. A timed set on Appeals and Revision shows your real accuracy, how long you take and where you lose marks.

Practise Appeals and RevisionFree diagnostic mock

More Appeals and Revision questions