Order u/s 148(d)

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This discussion clarifies whether an order issued under Section 148(d) of the Income Tax Act, 1961, can be revised under Section 264. The consensus is yes, provided the order is not subject to revision under Section 263. Section 264 allows for the revision of orders passed by subordinate authorities, including the Deputy Commissioner (Appeals), by the Principal Commissioner or Commissioner, either on their own motion or upon an assessee's application.

neetu

neetu (Querist)
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06 January 2023 Can an order u/s 148(d) be revised u/s 264 of the IT Act, 1961?

Dhirajlal Rambhia

Dhirajlal Rambhia (Expert)
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06 January 2023 Yes, any order other than an order to which section 263 applies can be revised u/s. 264 of IT act.

Bhaskaran Chackrapani Warrier

Bhaskaran Chackrapani Warrier (Expert)
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06 January 2023 148A(d) order is revisable.

Ram Avtar Singh

Ram Avtar Singh (Expert)
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06 January 2023 Orders other than Section 263
Section 264 (1) of the Act provides that in the case any order other than any order to which Section 263 applies passed by subordinate to him, the Principal Commissioner or Commissioner may, either of his own motion or on an application by the assessee for revision, call for the record of any proceeding under this Act in which any such order has been passed and may make such inquiry or cause such inquiry to be made and, subject to the provisions of this Act, may pass such order thereon, not being an order prejudicial to the assessee, as he thinks fit. The Deputy Commissioner (Appeals) shall be deemed to be an authority subordinate to the Principal Commissioner or Commissioner.

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