Chapter XXIII - Miscellaneous
Section 529
Section 529: power to withdraw approval
Section 529 confirms that any approval-granting authority under the Income-tax Act, 2025 - the Central Government, the Board, or an income-tax authority - can also withdraw that approval later, even where the specific provision under which it was granted doesn't expressly mention withdrawal.
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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
Where the Central Government or the Board or an income-tax authority, has the power to grant any approval under any provision of this Act to any assessee, the Central Government or the Board or such income-tax authority may, withdraw such approval at any time after recording the reasons therefor, even if such provision does not specifically allow for its withdrawal, after giving such assessee a reasonable opportunity of being heard.
Introduction
An authority empowered to grant an approval under the Act may also withdraw it, even when the approval-granting provision is silent about withdrawal.
Withdrawal requires recorded reasons and a reasonable opportunity for the assessee to be heard. Those procedural safeguards are part of the statutory power, not optional extras.
Key takeaways
Who may withdraw
The Central Government, Board or income-tax authority that has approval-granting power under the Act.
Express withdrawal clause not necessary
The power exists even where the particular approval provision does not itself mention withdrawal.
Two safeguards
Record reasons and give the assessee a reasonable opportunity of being heard before withdrawal.
What Section 529 says
"Where the Central Government or the Board or an income-tax authority, has the power to grant any approval under any provision of this Act to any assessee, the Central Government or the Board or such income-tax authority may, withdraw such approval at any time after recording the reasons therefor, even if such provision does not specifically allow for its withdrawal, after giving such assessee a reasonable opportunity of being heard."
Safeguards before withdrawal
- The reasons for withdrawal must be recorded
- The assessee must be given a reasonable opportunity of being heard before the approval is withdrawn
Applying Section 529 in practice
Safeguards. The Central Government, Board or income-tax authority that can grant an approval under the Act may withdraw it even if the specific grant provision does not repeat a withdrawal power. It must record reasons and give the assessee a reasonable opportunity of being heard.
Hypothetical example
A later compliance breach may prompt a withdrawal proposal, but the approval does not vanish merely because an officer informally asserts it.
Step-by-step flow for applying Section 529
- 1
Does the Central Government, the Board or an income-tax authority have power to grant an approval to the assessee under a provision of the Act?
- No: Section 529 does not apply.
- Yes: Go to the next step.
- 2
Does the provision itself allow withdrawal?
It does not matter. Section 529 allows withdrawal even if the provision does not specifically provide for it.
- 3
Were reasons for withdrawal recorded?
Section 529 requires the reasons to be recorded.
- 4
Was the assessee given a reasonable opportunity of being heard?
- No: The conditions of Section 529 are not met; the approval cannot be withdrawn under it.
- Yes, and reasons are recorded: The approval may be withdrawn at any time.
Practical checklist
Do
- Identify the original approval and the authority empowered to grant it.
- Review the recorded reasons and the opportunity given to respond before any withdrawal.
- approval instrument, granting authority, proposed grounds, hearing notice, response and reasoned withdrawal order.
Avoid
- Do not treat silence about withdrawal in the original approval provision as conclusive.
Illustrative example
Worked example: withdrawal of an approval
Hypothetical facts (illustration only, not a real taxpayer): An assessee holds an approval granted by an income-tax authority under a provision of the Act. The provision does not mention withdrawal. The authority believes the assessee is no longer meeting the basis on which approval was granted.
Power
The authority had power to grant the approval, so Section 529 lets it withdraw the approval even though the provision is silent.
Hearing
The authority gives the assessee a reasonable opportunity of being heard before deciding.
Reasons
The authority records its reasons for withdrawal.
Timing
Once these steps are followed, the approval may be withdrawn at any time.
Outcome
- The approval can be withdrawn after a hearing and recorded reasons.
- The assessee should use the hearing to answer the reasons put forward.
Glossary
- Withdrawal of approval
- Revocation by the Central Government, Board or granting authority under section 529 after the specified safeguards.
- Opportunity of being heard
- The assessee’s chance to respond before the authority withdraws the approval.
Frequently asked questions
Can an approval be withdrawn even if the section that granted it says nothing about withdrawal?
Yes - Section 529 allows withdrawal even if the specific provision under which the approval was granted does not specifically allow for withdrawal.
Does the assessee get a chance to respond before an approval is withdrawn?
Yes - the authority must record its reasons and give the assessee a reasonable opportunity of being heard before withdrawing the approval.
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Talk to our tax team about this sectionLast updated 10 October 2026