Section 24 explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
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.
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 assessee. The assessee's application is due within one year, extendable for sufficient cause to two years, and must carry the prescribed fee. The power does not extend to orders against which an appeal is still possible, is pending, or has been decided.
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.
| Feature | Section 23 | Section 24 |
|---|---|---|
| Orders covered | Orders that are erroneous and prejudicial to the revenue | Any other order, "other than an order to which section 23 applies" |
| Who starts it | The Principal Commissioner or the Commissioner | The Principal Commissioner or the Commissioner suo motu, or the assessee by application |
| Effect on the assessee | The revision order may enhance or modify the assessment | The 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).
| Step | Period (as enacted) |
|---|---|
| Ordinary window | One year from communication, or from knowledge of the order, whichever is earlier |
| Extended window, sufficient cause | After 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.
Read next
- Section 23: revision of orders prejudicial to revenue
- Sections 25-29: tax payable pending appeal and departmental appeals
- Sections 15-17: appeal to the Commissioner (Appeals)
- Revision on application by the assessee: the parallel income-tax procedure
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.
