Chapter XVIII - Appeals, Revisions and Alternate Dispute Resolutions
Section 378
Section 378: revision of other orders
Section 378 is the assessee-friendly counterpart to section 377 - it lets the Competent Authority revise any order (other than one covered by section 377) that is NOT prejudicial to the assessee, either on its own motion or on the assessee's application, subject to time limits, a ₹500 application fee, and restrictions where an appeal route is or was available.
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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.
Statutory text
Bare law
(1) The Competent Authority may, for any order, other than an order to which section 377 applies, passed by an authority subordinate to him, either of his own motion or on an application by the assessee for revision,–– (a) call for the record of any proceeding under this Act in which any such order has been passed; (b) make such inquiry or cause such inquiry to be made; and (c) subject to the provisions of this Act, pass such order thereon, not being an order prejudicial to the assessee, as he thinks fit.
(2) The Competent Authority shall not of his own motion revise any order under this section if the order has been made more than one year previously.
(3) An application for revision under this section shall be made by the assessee, within one year from the date on which the order in question was communicated to him or the date on which he otherwise came to know of it, whichever is earlier.
(4) The Competent Authority may, if he is satisfied that the assessee was prevented by sufficient cause from making the application within the period as provided in sub-section (3), admit an application made after the expiry of the period specified in that sub-section.
(5) The Competent Authority shall not revise any order under this section in the following cases:— (a) where an appeal against the order lies to the Joint Commissioner (Appeals) or the Commissioner (Appeals) or to the Appellate Tribunal, but has not been made and the time within which such appeal may be made has not expired; (b) where the appeal lies to the Joint Commissioner (Appeals) or the Commissioner (Appeals) or to the Appellate Tribunal, the assessee has not waived his right of appeal; or (c) where the order has been made the subject of an appeal to the Joint Commissioner (Appeals) or the Commissioner (Appeals) or to the Appellate Tribunal.
(6) Every application by an assessee for revision under this section shall be accompanied by a fee of ₹ 500.
(7) On every application by an assessee for revision under this section, an order shall be passed within one year from the end of the financial year in which such application is made.
(8) In computing the period of limitation under sub-section (7), the following period shall be excluded:— (a) the time taken in giving an opportunity to the assessee to be reheard under section 244(2); and (b) the period commencing on the date on which stay on any proceeding under this section has been granted by an order or injunction of any court and ending on the date on which certified copy of the order or injunction vacating the stay is received by the jurisdictional Principal Commissioner or Commissioner.
(9) If after the exclusion of the period provided in sub-section (8), the time limit for completion as provided in sub-section (7) is less than sixty days, such remaining period shall be extended to sixty days and such period of limitation shall be deemed to have been extended accordingly.
(10) Irrespective of anything contained in sub-section (7), an order in revision under that sub-section may be passed at any time in consequence of or to give effect to any finding or direction contained in an order of the Appellate Tribunal, the High Court or the Supreme Court.
(11) For the purposes of this section,–– (a) “Competent Authority” means the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner; (b) an order by the Competent Authority declining to interfere shall, not be deemed to be an order prejudicial to the assessee.
Introduction
This revision route concerns a subordinate authority’s order outside section 377. It can start on the competent authority’s own motion or on the assessee’s application, and the resulting revision order may not prejudice the assessee.
An assessee choosing this route must check both the one-year application period and the relationship with any available appeal. An existing appeal, an unexpired appeal period, or an unwaived right of appeal can bar revision under subsection (5).
Key takeaways
Different revision route
This section covers subordinate-authority orders other than those governed by section 377.
No prejudicial revision
The competent authority’s order under subsection (1) may not be prejudicial to the assessee.
Application timing
An assessee ordinarily applies within one year of communication or earlier knowledge of the order, subject to sufficient-cause admission.
The revision power
For any order other than one to which section 377 applies, passed by an authority subordinate to it, the Competent Authority may - either on its own motion or on the assessee's application - call for the record of the proceeding, make or cause an inquiry to be made, and pass such order as it thinks fit, so long as that order is not prejudicial to the assessee.
Time limits
The Competent Authority cannot, of its own motion, revise an order made more than one year previously.
An assessee's application for revision must be made within one year from the date the order was communicated, or the date the assessee otherwise came to know of it, whichever is earlier - though the Competent Authority may admit a late application if satisfied there was sufficient cause for the delay.
On every application, an order must be passed within one year from the end of the financial year in which the application was made, though time taken for a fresh hearing under section 244(2) and any court-stay period are excluded from this limit (with the remaining period extended to sixty days if it would otherwise be shorter).
Irrespective of the one-year limit for passing an order, a revision may be passed at any time in consequence of, or to give effect to, a finding or direction in an order of the Appellate Tribunal, High Court or Supreme Court.
When revision under this section is not available
The Competent Authority cannot revise an order under this section where: an appeal against it lies to the Joint Commissioner (Appeals), Commissioner (Appeals) or Appellate Tribunal but has not been filed and the time to appeal has not expired; the assessee has not waived the right of appeal; or the order has already been made the subject of such an appeal.
Fee and definitions
Every application by an assessee for revision under this section must be accompanied by a fee of ₹500.
"Competent Authority" means the Principal Chief Commissioner, Chief Commissioner, Principal Commissioner or Commissioner.
An order by the Competent Authority declining to interfere is NOT deemed to be an order prejudicial to the assessee.
Step-by-step flow for revision under Section 378
- 1
Is the order one passed by an authority subordinate to the Competent Authority, and not an order to which section 377 applies?
- No: Section 378 does not apply.
- Yes: Go to the next step.
- 2
Does the appeal route block revision under Section 378(5)?
Revision is not allowed if an appeal lies to the Joint Commissioner (Appeals), Commissioner (Appeals) or Appellate Tribunal and the time for it has not expired, or if such an appeal lies and the assessee has not waived the right of appeal, or if the order is already the subject of such an appeal.
- Yes: The Competent Authority cannot revise the order.
- No: Go to the next step.
- 3
Who starts the revision?
- Competent Authority on its own motion: Allowed only if the order was made not more than one year earlier (Section 378(2)). Go to step 5.
- Assessee's application: Go to the next step.
- 4
Is the assessee's application in time and complete?
It must be made within one year from the date the order was communicated or the date the assessee otherwise came to know of it, whichever is earlier (Section 378(3)). A late application may be admitted for sufficient cause (Section 378(4)). It must carry a fee of ₹500 (Section 378(6)).
- 5
Inquiry and order
The Competent Authority calls for the record, makes inquiry and passes an order that is not prejudicial to the assessee. On an application, the order must be passed within one year from the end of the financial year in which the application is made, subject to the exclusions and sixty-day extension in Section 378(8) and (9), and to Section 378(10). An order declining to interfere is not treated as prejudicial (Section 378(11)(b)).
Practical checklist
Do
- Identify the order, its communication date and any earlier date on which it became known; calculate the one-year application period from the earlier date.
- Check appeal availability and whether the appeal right must be waived before applying.
- Include the ₹500 fee and evidence supporting the requested change; explain any sufficient cause if filing late.
Avoid
- Do not pursue this route for an order governed by section 377.
- Do not assume a pending or already-used appeal can be run alongside revision of the same order.
Illustrative example
Worked example: an assessee applies for revision
Hypothetical facts (illustration only, not a real taxpayer): An order of a subordinate authority is communicated to an individual on 10 August 2027. It is not an order to which section 377 applies. An appeal lies against it, but the individual waives the right of appeal and does not file one. On 5 January 2028 the individual applies to the Competent Authority for revision. The dates are assumed for illustration.
Appeal bar
The time for filing an appeal against the order has expired, the individual has waived the right of appeal, and no appeal has been made, so none of the bars in Section 378(5) applies.
Application time
The application must be made within one year of 10 August 2027. Filing on 5 January 2028 is within that time.
Fee
The application is accompanied by the fee of ₹500 required by Section 378(6).
Time for the order
The application is made in the financial year ending 31 March 2028. The order must be passed within one year from that date, i.e. by 31 March 2029, subject to Section 378(8) and (9).
Nature of the order
The Competent Authority may pass any order it thinks fit that is not prejudicial to the assessee, or may decline to interfere.
Outcome
- The revision application is valid and must be decided by 31 March 2029, subject to the exclusions.
- Revision under Section 378 cannot leave the individual worse off.
Glossary
- Own-motion revision
- Revision initiated by the competent authority rather than by the assessee’s application.
- Sufficient cause
- The statutory basis on which the authority may admit an assessee application made after the one-year period.
Frequently asked questions
What is the fee for applying for revision under Section 378?
₹500, as set out in Section 378(6).
Can I apply for revision under Section 378 if I could still appeal the order instead?
No - Section 378(5) blocks revision where an appeal against the order still lies (and the appeal period hasn't expired), where the assessee hasn't waived the right of appeal, or where the order has already been made the subject of an appeal.
How long do I have to apply for revision of an order under Section 378?
One year from the date the order was communicated to you, or the date you otherwise came to know of it, whichever is earlier - though a late application can be admitted for sufficient cause.
Need help applying this provision to your situation?
Get help filing your revision applicationLast updated 10 October 2026