The Commissioner of Income tax has no power to revise an assessment on subjects that are debatable in nature.
In tax report [2026] 183 taxmann.com 97 (Mumbai – Trib.)[02-02-2026] the Tribunal found a favourable order from the CIT(A) in subsequent year on similar issue for which reason it held that the issue is debatable and no revision can be made as there was no prejudice caused to the interest of the revenue.
Whereas further in the recent budget for 2026 it is suggested in the memorandum that updated return may also be allowed in such cases where proceedings of reassessment have been initiated and notice of reassessment has been issued under section 280 of the Act but there is no similar route available to taxpayer when the Commissioner so chooses to initiate revision under new section 377.
Since the object is to reduce litigation only the same should have been expanded to revision too.