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

Sundaram Textiles Ltd received an assessment order from the Assessing Officer. The company did not file any appeal before the Commissioner (Appeals), and the time allowed for filing such an appeal has not yet expired. The company now applies to the Principal Commissioner for revision of that order under section 378 of the Income-tax Act, 2025. Which statement is correct?

The Principal Commissioner cannot revise the order. Section 378(5)(a) bars revision where an appeal lies to the Commissioner (Appeals) but has not been filed and the time limit for filing it has not expired. Merely not having filed an appeal does not open the revision route.

  1. AThe Principal Commissioner can revise the order because the company has not filed any appeal
  2. BThe Principal Commissioner cannot revise the order, because an appeal lies to the Commissioner (Appeals) and the time to file it has not expiredCorrect
  3. CThe Principal Commissioner can revise the order only if the fee of Rs. 500 is waived
  4. DThe Principal Commissioner can revise the order only if the Tribunal permits it

Explanation

Under section 378(5)(a), the Competent Authority cannot revise an order where an appeal lies to the Commissioner (Appeals) or the Tribunal but has not been made and the time to make it has not expired. Since the appeal window is still open, revision is barred. The first option ignores this bar.

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