How revision can be a boon for taxpayers?

Taxpayers, otherwise deprived of adequate remedy, can opt for revision before Income-Tax Commissioner

- JIGAR MUKESH PATEL

Section 264 of the Income-tax Act is an equitable or beneficial provision which can provide meaningful relief to a taxpayer in situations where he may otherwise be deprived of adequate remedy.

Powers of revision in the interest of taxpayer Under section 264, an Income-tax Commissioner is empowered to exercise powers of revision in the interest of the taxpayer. In the exercise of this power, the Commissioner may either of his own motion or on an application by the taxpayer, call for the record of any income tax proceeding and pass such order thereon, not being an order prejudicial to the taxpayer.

The revisionary power by the Commissioner is to be exercised within a limitation of one year, either in case of a suo motu action or at the instance of the taxpayer, with the added discretion to condone delay in a case where he is satisfied that the taxpayer was prevented by sufficient cause from preferring an application within the prescribed period.