Revision Proceedings u/s 263 and Revision Application u/s 264

Sections of the Income-tax Act, 2025 are shown next to the 1961 Act sections.

Under Section 2632025 Act: s. 377, the Principal Commissioner can revise an order that is both erroneous and prejudicial to the interests of revenue. Under Section 2642025 Act: s. 378, a taxpayer can apply to the Commissioner for revision of an order in their favour.

Income Tax, across India (faceless)

Income-tax Act, 1961

This page is for notices and orders under the Income-tax Act, 1961. If yours names the Income-tax Act, 2025, see Revision u/s 377 / 378 (2025 Act). Not sure which Act applies? The heading of the notice names it, or call us.

Overview

A 263 notice can be resisted where the AO took a possible view after enquiry. A 264 application is useful where an appeal is not filed and relief is still due.

When this applies

  • PCIT considers the assessment was made without enquiry
  • Audit objections on assessments
  • Taxpayer seeking relief through 264 without appeal

Time limit

Section 2632025 Act: s. 377 orders: within two years from the end of the financial year in which the original order was passed. Section 2642025 Act: s. 378 applications: within one year from the date of the order (condonable).

Documents needed

  • Assessment record showing enquiries made
  • 263 notice or order sought to be revised

How we handle it

  1. Show the enquiries made and the view taken by the AO
  2. Draft the reply with case laws on ‘possible view’
  3. Appeal before ITAT against a 263 order
  4. Draft and file 264 applications where useful

Points to note

  • The assessment record is key. Collect all replies and notices
  • 264 is not available if an appeal is pending or the appeal time has not expired

What usually comes next

Frequently asked questions

Can a 263 order be appealed?

Yes, before the Income Tax Appellate Tribunal.

Official sources

Received a notice or an order?

Call us to talk it through. Keep the notice and its response date handy.

Related services

← All Income Tax Appeals