Administrative Remedies under the Indian Tax Law : Clause 378 of the Income Tax Bill, 2025 Vs. Section 264 of the Income-tax Act, 1961

Revisionary jurisdiction prevents orders prejudicial to the assessee while ensuring timely administrative review and minimum processing time.

Clause 378 empowers senior tax officials as the Competent Authority to revise subordinate orders suo motu or on application, provided any revision is not prejudicial to the assessee. It prescribes one year limitation periods for initiation, allows condonation for sufficient cause, requires a nominal application fee, mandates disposal within a year from the end of the financial year of filing with specified exclusions for rehearings and judicial stays, and introduces a minimum sixty day residual period after exclusions for completion of revision.