TaxTMI 
TaxTMI 
28 Oct 2026 
Abbreviations used:
ITA 1961 or 61 Act - The income-tax Act, 1961
ITA 2025 or 25 Act - The income-tax Act, 2025
ITR 1962 or 62 Rules - Income Tax Rules 1962
ITR 2026 Or Rules 2026- Income-tax rules 2026
PY - Previous year in ITA 1961
AY- Assessment year in ITA 1961.
TY - Tax year in ITA 2025
In the table below comparison is made for corresponding provisions in two enactments.
| Remarks | ||
| Power to withdraw approval.
| 1[Power to withdraw approval.
| Similar |
| Note- it is one para but divided for analysis per author | Note- it is one para but divided for analysis, stated in matching manner. - per author |
|
| 529. 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, | 293C. Where the Central Government or the Board or an income-tax authority, who has been conferred upon the power under any provision of this Act to grant any approval to any assessee, the Central Government or the Board or such authority may, | Similar in effect |
| withdraw such approval at any time after recording the reasons therefor, | withdraw such approval at any time: (taken from proviso for matching - per author) at any time, withdraw the approval after recording the reasons for doing so.]
| Similar effect, but subject to style of drafting and words used. |
| even if such provision does not specifically allow for its withdrawal, | notwithstanding that a provision to withdraw such approval has not been specifically provided for in such provision, |
|
| after giving such assessee a reasonable opportunity of being heard.
| Provided that the Central Government or Board or income-tax authority shall, after giving a reasonable opportunity of showing cause against the proposed withdrawal to the assessee concerned, |
|
There is difference of style of drafting and words used. It seems that intention is the same, however, differences can be a reason for litigation and not following settled legal position under ITA 1961.
The purpose of the provisions is to provide a shield to tax authorities and make it easy to withdraw approvals, although provision is made for providing an opportunity to concerned assessee, but experience shows that it is used as a tool to make compliance and orders for withdrawal are taken routinely.
The power given is wide and is irrespective of whether there is such power or not in the relevant provision under which approval was granted.
Such wide powers to withdraw is not proper. In fact, the efforts should be to ensure that approvals are granted with due care.
Language could be simplified by use of words Central Government and any income-tax authority because of definition of income-tax authority. There is no harm, even if inspector of income tax (ITI) is included because in some cases assessee can possibly claim / establish that the withdrawal was by ITI, though signed by any other authority. For example, if withdrawal was initiated and is mainly based on report of ITI.
The grapevine is that even in these days of faceless proceedings or proceedings requiring minimal interaction there is / possibility of corruption while granting approvals and also with power to withdraw approvals.
Litigation about S. 293C which was Inserted vide Section 79 of the Finance (No.2) Act, 2009 w.e.f. 01-10-2009 has faced some litigation before ITAT on wards. For example, as per reports on this website we find following search results.
Showing Results for : Law: Income Tax Statute: Income-tax Act, 1961 Section: Section 293C 20 Results
Showing Results for : Law: Income Tax Favour : In favour of Assessee Statute: Income-tax Act, 1961 Section: Section 293C 17 Results
Law: Income TaxCourts: High Court Statute: Income-tax Act, 1961 Section: Section 293C 3 Results
Showing Results for : Law: Income TaxCourts: Supreme Court - All Statute: Income-tax Act, 1961 Section: Section 293C 0 Results
The above results are not exhaustive because all cases are not reported.
Law: Income Tax Party Name: Commissioner (Exemption) Sort : default Search In : Main Text + AI Text 303 Results
Law: Income Tax Favour : In favour of Assessee Party Name: Commissioner (Exemption) Sort : default Search In : Main Text + AI Text
Searched Text : approval 219 Results
Law: Income Tax Party Name: Commissioner (Exemption) Sort : default Search In : Main Text + AI Text
Searched Text : approval withdrawal 25 Results
The above results are illustrative only.