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Chapter XVI - Procedure for Assessment

Section 283

Section 283: reassessment to give effect to an appeal, revision or court order

Section 283 is an exception to the ordinary time limits in Section 282 for a Section 280 notice needed to give effect to a specified finding or direction of an authority, Tribunal, Court or the Approving Panel. The amended provision also prevents revival of certain already time-barred years and requires the notice within three months from the end of the quarter in which the certified order is received by the jurisdictional Principal Commissioner or Commissioner.

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Need advice on Section 283?

This article is for general information. Refer to the Income-tax Act, 2025 as amended by the Finance Act, 2026 and the Taxation and Other Laws (Amendment) Act, 2026 for the official provisions. If you need professional advice for your situation, contact Bizeneed.

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Statutory text

Bare law

(1) Irrespective of anything contained in section 282, the notice under section 280 may be issued at any time for the purpose of making an assessment or reassessment or recomputation in consequence of, or to give effect to,—

(a) any finding or direction contained in an order passed by any authority, Tribunal or Court in any proceeding under this Act or any other law; or

(b) the directions issued by the Approving Panel under section 274(6).

(2) The provisions of sub-section (1) shall not apply in any case, where the assessment or reassessment or recomputation as is referred to in that sub-section relates to a tax year in respect of which an assessment or reassessment or recomputation could not have been made under this Act due to it being time-barred, at the time when,—

(a) the order, which was the subject matter before any authority, Tribunal or Court, was made; or

(b) the proceedings relating to assessment or reassessment or recomputation under this Act (other than those proceedings which have culminated in an order), which was the subject matter before the Court, was initiated; or

(c) the reference from the jurisdictional Principal Commissioner or Commissioner is made to the Approving Panel under section 274(4).

(3) For the purposes of sub-section (1), notice under section 280 shall be issued within three months from the end of the quarter in which the certified copy of the order of the authority or the Court, as the case may be, is received by the jurisdictional Principal Commissioner or Commissioner.

Introduction

Section 283 addresses reassessment notices issued to give effect to specified findings or directions even where the ordinary section 282 limit would otherwise apply.

It does not revive a year already time-barred under the stated safeguard, and has its own issue deadline.

Key takeaways

1

Giving effect to later directions

A section 280 notice can be issued to implement qualifying findings or directions of an authority, Tribunal, Court or Approving Panel despite the ordinary section 282 limit.

2

Already-barred years stay protected

The substituted section does not reopen a year that was already time-barred at the relevant earlier event.

3

Separate three-month deadline

The notice must issue within three months from the end of the quarter in which the certified order is received by the jurisdictional Principal Commissioner or Commissioner.

When the ordinary Section 282 limit is overridden

Irrespective of the ordinary time limits in section 282, a notice under section 280 may be issued to make an assessment, reassessment or recomputation in consequence of, or to give effect to the following. The separate deadline in section 283(3) still applies:

  • any finding or direction contained in an order passed by any authority, Tribunal or Court in any proceeding under this Act or any other law; or
  • directions issued by the Approving Panel under section 274(6).

Safeguard: cannot revive an already time-barred year

This override does not apply where the assessment, reassessment or recomputation relates to a tax year that could not have been assessed under the Act because it was already time-barred at the relevant time - namely, when the order that was the subject-matter before the authority/Tribunal/Court was made, when the underlying proceedings (other than those culminating in an order) that were the subject-matter before the Court were initiated, or when the reference to the Approving Panel was made by the jurisdictional Principal Commissioner or Commissioner under section 274(4).

Time limit for issuing the notice itself

Where this section applies, the notice under section 280 must be issued within three months from the end of the quarter in which the certified copy of the order of the authority or Court is received by the jurisdictional Principal Commissioner or Commissioner.

Step-by-step flow for a notice under Section 283

  1. 1

    Is the Section 280 notice needed to give effect to a qualifying finding or direction?

    Section 283(1) covers a finding or direction in an order of any authority, Tribunal or Court in a proceeding under this Act or any other law, and directions of the Approving Panel under Section 274(6).

    • No: Section 283 does not apply. The ordinary limits in Section 282 govern the notice.
    • Yes: Go to the next step.
  2. 2

    Was the tax year already time-barred at the relevant earlier point?

    Under Section 283(2), check the year's status when the order that was the subject matter before the authority, Tribunal or Court was made; when the underlying proceeding before the Court was initiated (if it had not ended in an order); or when the reference to the Approving Panel was made under Section 274(4).

    • Yes: Section 283(1) does not apply to that year. It cannot be revived.
    • No: Go to the next step.
  3. 3

    When did the jurisdictional Principal Commissioner or Commissioner receive the certified copy of the order?

    Note the date of receipt and the quarter in which it falls.

  4. 4

    Issue the notice within three months from the end of that quarter

    Section 283(3) sets this outer limit. Within it, the Section 282 limits do not stop the notice.

Practical checklist

Do

  • Identify the exact appellate or court finding or direction relied on.
  • Check the statutory limitation and already-barred-year safeguard.

Avoid

  • Assume every old year can be reopened merely because a later order mentions it.

Illustrative example

Worked example: income shifted to another year by a Tribunal order

Hypothetical facts (illustration only, not a real taxpayer): In an appeal for tax year 2027-28, the Tribunal finds that a receipt of ₹22 lakh (assumed figure) belongs to tax year 2028-29, not 2027-28. The certified copy of the order is received by the jurisdictional Principal Commissioner on 10 August 2030 (assumed date).

  1. Qualifying direction

    The finding is in a Tribunal order in a proceeding under the Act, so Section 283(1)(a) can apply to a notice for tax year 2028-29.

  2. Time-bar check

    Tax year 2028-29 must not have been time-barred when the order that was the subject matter of the appeal was made (Section 283(2)(a)). It ended on 31 March 2029, so on these assumed dates it was not barred.

  3. Quarter of receipt

    10 August 2030 falls in the quarter from 1 July to 30 September 2030.

  4. Deadline

    Three months from 30 September 2030 ends on 31 December 2030. The Section 280 notice for tax year 2028-29 must be issued by then.

Outcome

  • The notice for tax year 2028-29 can be issued up to 31 December 2030, whatever the Section 282 position.
  • If the notice is issued later, Section 283 does not support it.

Frequently asked questions

Can a reassessment notice be issued after the normal time limit under Section 282?

Yes, for a qualifying finding or direction in an authority, Tribunal or Court order, or an Approving Panel direction under section 274(6). The ordinary Section 282 limit is overridden, but section 283(3) requires the notice within three months from the end of the quarter in which the certified order is received by the jurisdictional Principal Commissioner or Commissioner.

Is there any limit on this override?

Yes - it cannot be used to reassess a tax year that was already time-barred at the point the underlying order was passed or the underlying court proceeding was initiated, or when the Approving Panel reference was made.

How quickly must the notice be issued once the order is received?

Within three months from the end of the quarter in which the certified copy of the authority's or Court's order is received by the jurisdictional Principal Commissioner or Commissioner.

Need help applying this provision to your situation?

Get help with a reassessment notice following an appeal order

Last updated 9 October 2026