Section 284: sanction for issue of notice

Introduction

Section 284 identifies the “specified authority” for the purposes of sections 280 and 281 in the reassessment framework. It names four possible offices: Additional Commissioner, Additional Director, Joint Commissioner and Joint Director.

The section identifies the competent level of authority. The grounds, process and timing for a notice are governed by the connected sections; section 284 does not itself establish those requirements.

Key takeaways

Who is the specified authority

The specified authority for the purposes of sections 280 and 281 is the Additional Commissioner or the Additional Director or the Joint Commissioner or the Joint Director.

Scope and practical relevance

Section 284 answers who is the specified authority. To identify when approval is needed, read the operative approval requirement in Section 280 or 281. The authority’s designation and the approval stage are related but different checks.

Section 281(3) concerns prior approval for the order deciding whether it is a fit case to issue a Section 280 notice. In the listed cases covered by Section 280(5), prior approval is required before that notice; Section 281(4) excludes those cases from its show-cause procedure.

Limits and separate requirements

Do not assume that every reassessment case follows one identical approval sequence. Identify the relevant statutory route before checking the officer and dates.

Section 284 does not itself establish the information suggesting escaped income, a notice deadline or the eventual tax liability. Approval from a named authority does not eliminate the need to check those separate conditions.

Step-by-step assessment review

1. Identify whether the action being examined is a Section 281(3) order or a notice subject to Section 280(5).

2. Match the approving officer’s designation to the four offices in Section 284.

3. Compare the approval reference and date with the action for which prior approval is required.

4. Keep the approval issue separate from the information, hearing and limitation questions under the connected provisions.

Hypothetical assessment example

Hypothetical illustration: a taxpayer receives an order under Section 281(3) followed by a reassessment notice. A reviewer checks the authority and timing of approval for that order. If the case instead falls within Section 280(5), the relevant approval check is before the notice under that route. Section 284 supplies the designated offices for both checks, not a single interchangeable document sequence.

Documents and reconciliation checklist

The relevant notice or order and its statutory provision.

The approval reference, approving designation and dates available in the record.

A chronology showing which reassessment route is being followed.

Official amended Act source

• Income-tax Act, 2025 as amended by Finance Act, 2026: Section 284 and connected provisions

Step-by-step flow for identifying the specified authority under Section 284

1. 1

   Which approval is in question?

   The specified authority gives prior approval for the order under Section 281(3) and for a Section 280 notice in the cases listed in Section 280(5).

2. 2

   Who is the specified authority?

   Section 284 names the Additional Commissioner, the Additional Director, the Joint Commissioner or the Joint Director.

3. 3

   Was the approval given by one of those officers?

   Check the designation of the approving officer on the order or notice record.

   • Yes: The rank requirement of Section 284 is met.
   • No, or not shown: Note this as a point to raise in the reply or proceeding.
4. 4

   Check the other conditions separately

   Section 284 only names the authority. Time limits come from Sections 282 and 283, and the procedure from Sections 280 and 281.

Practical checklist

Glossary

Specified authority

One of the Additional Commissioner, Additional Director, Joint Commissioner or Joint Director offices named in Section 284.

Prior approval

Approval before the action for which the operative provision requires it.

Frequently asked questions