Answer

ITR

Revision of a reassessment order

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  1. Facts

    Yes. Any order passed by the assessing officer, including a reassessment order, can be revised if it is erroneous and prejudicial to revenue, within the time limit.

  2. Provisions and law

    • Sec 263, Income-tax Act 1961 (now Sec 377, Income-tax Act 2025)The Principal Commissioner or Commissioner can revise an assessment order that is erroneous and prejudicial to revenue, after giving a hearing, within 2 years from the end of the financial year of the order.
    • Sec 147, Income-tax Act 1961 (now Sec 279, Income-tax Act 2025)Reassessment of income escaping assessment.
  3. Analysis

    The 2-year limit runs from the end of the financial year in which the reassessment order was passed. Check which issues the revision targets; issues not part of the reassessment may be outside scope. Gather the reassessment records. Use the same defences.

  4. Conclusion

    1. Identify which order is being revised.
    2. Check the time limit from that order.
    3. Check the issues against the reassessment scope.
    4. Reply with records.

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Revision, Sec 263 (now 377)

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