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CS Executive · Tax Laws and Practice · Procedural Compliance under Income Tax

Under section 378 of the Income-tax Act, 2025, an order was passed by the Assessing Officer on 10 June 2026. The Principal Commissioner wants to revise it of his own motion. Which statement is correct?

The Principal Commissioner can revise suo motu only if the order was made not more than one year earlier. Section 378(2) prohibits own-motion revision of an order older than one year. The four-year period applies to rectification of mistakes, not to this revision power.

  1. AHe may revise it any time within four years, as in rectification
  2. BHe may revise it only if the order was made not more than one year previouslyCorrect
  3. CHe may revise it only if the assessee consents in writing
  4. DHe may revise it only after the Appellate Tribunal has decided the matter

Explanation

Section 378(2) bars suo motu revision of an order made more than one year previously. The four-year limit belongs to rectification under section 287(8), so it is the key distractor. Neither the assessee's consent nor a Tribunal decision is required.

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