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Section 24 of the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015: revision of other orders, on the assessee's application or suo motu

For any order other than one to which section 23 applies, the Principal Commissioner or the Commissioner may call for records and pass an order that is not prejudicial to the...

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Published
October 2, 2026
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Last updated: October 2026Verified against: Government sources

Section 24 is the second revision section. Where section 23 deals with orders that harm the revenue, section 24 deals with every other order. The Principal Commissioner or the Commissioner may revise it on his own motion or on the assessee's application, but only to pass an order that is not prejudicial to the assessee. This article reads the section as the Act as enacted and published in the Gazette of India on 27 May 2015 prints it.

Sub-section (1) and (2): the power

Section 24(1) says the Principal Commissioner or the Commissioner may, "either suo motu or on an application made by the assessee", for the purposes of revising any order passed by an authority subordinate to him, other than an order to which section 23 applies, call for and examine all available records relating to it.

Section 24(2) says he may pass an order as he considers necessary, "which is not prejudicial to the assessee". So the section can only help the assessee or leave the assessee where he was. Sub-section (9) reinforces this: an order declining to interfere shall, for the purposes of the section, be deemed not to be an order prejudicial to the assessee.

FeatureSection 23Section 24
Orders coveredOrders that are erroneous and prejudicial to the revenueAny other order, "other than an order to which section 23 applies"
Who starts itThe Principal Commissioner or the CommissionerThe Principal Commissioner or the Commissioner suo motu, or the assessee by application
Effect on the assesseeThe revision order may enhance or modify the assessmentThe revision order must not be prejudicial to the assessee

Our article on section 23 explains the first column.

Sub-section (3): orders the power does not reach

The power under sub-section (2) shall not extend to an order:

  • (a) against which an appeal has not been filed but the time for filing an appeal before the Commissioner (Appeals) has not expired;
  • (b) against which an appeal is pending before the Commissioner (Appeals); or
  • (c) which has been considered and decided in any appeal.

The result is a clear order of use. While the first appeal is open or pending, revision is not available. The assessee has to choose. If you are weighing revision against appeal, a legal dispute resolution adviser can help you compare the two on your facts. The appeal route is in sections 15 to 17.

Sub-section (4) and (5): the application window

Section 24(4) says the assessee shall make the application for revision of any order referred to in sub-section (1) within a period of one year from the date on which the order sought to be revised was communicated to him, or the date on which he otherwise came to know of it, whichever is earlier.

Section 24(5) says that if he is satisfied that the assessee was prevented by sufficient cause from making the application within the one year, the Principal Commissioner or the Commissioner may admit an application made after one year but before the expiry of two years from the date referred to in sub-section (4).

StepPeriod (as enacted)
Ordinary windowOne year from communication, or from knowledge of the order, whichever is earlier
Extended window, sufficient causeAfter one year but before two years from the same date

The words "whichever is earlier" matter: if you learned of the order before it was formally communicated, the year runs from the earlier date.

Sub-section (6): the fee

Every application by an assessee for revision under the section shall be accompanied by such fees as may be prescribed. The Act leaves the amount to rules. The Rules of 2015, as notified on 2 July 2015, as printed do not mention revision or section 24, so the Act and the Rules are silent on the amount; check any later amendment rules before applying.

Sub-section (7) and (8): when the order must be made

Section 24(7) says no order under sub-section (2) shall be made after the expiry of:

  • (a) a period of one year from the end of the financial year in which an application is made by the assessee under sub-section (4); or
  • (b) a period of one year from the date of the order sought to be revised, if the order is revised suo motu by the Commissioner.

Section 24(8) excludes from the computation under sub-section (7):

  • (a) the time taken in giving an opportunity to the assessee to be reheard under section 7; or
  • (b) any period during which any proceeding under this section is stayed by an order or injunction of any court.

The time limits therefore run in two directions. The assessee has one year (or two with sufficient cause) to apply, and the Commissioner has one year from the end of the financial year of the application to decide. For the rehearing in clause (a), see section 7.

The parallel income-tax route

Income-tax law has its own revision on the assessee's application. For that parallel procedure, see our guide on revision on application by the assessee.

An example

An order is passed against Kavita Nair and communicated to her on 20 July. She does not appeal and the time to appeal to the Commissioner (Appeals) expires. She applies to the Principal Commissioner for revision with the prescribed fee, within one year from 20 July. The Principal Commissioner calls for the records and passes an order that reduces the sum payable. Under section 24(2), the order is not prejudicial to her. Had she applied while an appeal against the order was pending before the Commissioner (Appeals), section 24(3)(b) would have barred the revision. Had she applied fourteen months after the date, she would have needed to show sufficient cause, and the application would have to be admitted before the end of two years from that date.

Need help with a revision application?

A revision application is only useful if the order is within time, no appeal is pending and the grounds are clear. Our legal dispute resolution team can help you check each of these, draft the application and follow it up.

Key takeaways

  • Section 24 covers orders other than those to which section 23 applies, and can be started suo motu or on the assessee's application.
  • The order passed must not be prejudicial to the assessee.
  • Revision is not available while an appeal before the Commissioner (Appeals) is open or pending, or after the order has been decided in an appeal.
  • The application is due within one year, admitted up to two years for sufficient cause, and carries the prescribed fee.
  • The order must be made within one year from the end of the financial year of the application, or one year from the order if revised suo motu, with exclusions.
  • Later Finance Act amendments to section 24, and any amendment rules, must be checked before acting. The Act cites no section of the Income-tax Act here; where income-tax law is mentioned, it means the Income-tax Act, 1961 as printed in 2015, and the corresponding provision of the current income-tax law should be checked.

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Disclaimer: Based on the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 as enacted and published in the Gazette of India on 27 May 2015, and on the Rules of 2015 as notified on 2 July 2015, as consulted on 2 October 2026. Later Finance Act amendments, amendment rules and the current income-tax law should be checked. This article is general information, not legal advice; check the official text before acting.

Quick recapKey facts & short answers

Key Facts About Section 24

  • Applies in: All states across India, under the relevant central law.
  • Mode: Mostly online via the official government portal.
  • Typical timeline: Ranges from a few days to a few weeks depending on the case.
  • Non-compliance: May attract penalties, interest or late fees.
  • Expert help: TaxClue completes the entire process end to end for you.

Who can ask for revision under section 24?

The assessee, by an application; the Principal Commissioner or the Commissioner can also act suo motu.

What can the revision order do?

Section 24(2) says it can be such an order as he considers necessary, which is not prejudicial to the assessee.

Paperwork done properly once does not have to be done again under pressure.

— TaxClue Compliance Desk

Section 24: a key compliance topic in Indian tax and corporate law that businesses and individuals must understand to remain compliant.

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Disclaimer: This article is for general informational purposes only and does not constitute professional tax, legal or financial advice. Laws, rates and due dates change and can vary by individual case — always verify with the relevant government source (e.g. mca.gov.in, incometax.gov.in) or consult a qualified professional before acting. TaxClue accepts no liability for decisions taken based on this content.

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Questions, answered

Short, direct answers to the 6 questions readers ask most on this topic.

The assessee, by an application; the Principal Commissioner or the Commissioner can also act suo motu.

Section 24(2) says it can be such an order as he considers necessary, which is not prejudicial to the assessee.

No. Section 24(3)(b) excludes an order against which an appeal is pending before the Commissioner (Appeals).

One year from the communication of the order or the date you otherwise came to know of it, whichever is earlier, with admission up to two years for sufficient cause.

Section 24(6) says such fees as may be prescribed. The amount is left to rules.

Section 24(9) deems such an order not to be prejudicial to the assessee.