ITR
Revision of a reassessment order
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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.
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.
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.
Conclusion
- Identify which order is being revised.
- Check the time limit from that order.
- Check the issues against the reassessment scope.
- Reply with records.
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Revision, Sec 263 (now 377)
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