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Appeal

Section 264 Revision Application — Seeking Relief from the Commissioner

Section 264 allows taxpayers to file a revision application with the CIT for any order passed by a subordinate authority. This is an alternative remedy when appeal is not feasible or time-barred.

Response Deadline
1 year from the date of the order
Extension
Not available
New IT Act
Section 264

What Does This Notice Mean?

You can ask the CIT to revise any order in your favor. This is useful when you missed the appeal deadline, when the issue does not fall under 154, or when you need a sympathetic hearing. The CIT has wide discretion under 264.

Common Triggers

  • Appeal deadline under 246A missed
  • Issue is not a "mistake apparent" for 154 rectification
  • Need to claim a deduction/exemption not claimed in the original return
  • Order is incorrect but no statutory appeal is available

How to Respond

  1. 1File application within 1 year from the date of the order
  2. 2Pay the prescribed fee of Rs 500
  3. 3Draft a detailed petition explaining the error and the relief sought
  4. 4Attach all supporting documents
  5. 5Note: 264 cannot be filed if the issue is pending in appeal or has been decided in appeal

Consequences of Non-Compliance

The CIT can modify, enhance, or cancel the order. This is a discretionary power — the CIT is not bound to grant relief.

Frequently Asked Questions

When should I use Section 264 instead of filing an appeal?

Use 264 when you missed the 30-day appeal deadline, when the order cannot be rectified under 154, or when you want to claim something not included in your original return. The 264 time limit is 1 year.

Related Sections

Section 154
Rectification
Section 246A
Appeal to CIT(A)
Section 263
CIT Revision

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Disclaimer: This content is for informational purposes only and does not constitute legal or tax advice. Always consult a qualified Chartered Accountant or tax professional for advice specific to your situation. AI-generated content should be reviewed by a professional before use.