The section gives the Board a single power: to direct, by notification, that any income-tax authority or authorities specified in the notification shall be subordinate to such other income-tax authority or authorities as are specified in that notification. Subordination is therefore fixed by notification rather than by the section itself.
Why it is there
The Act repeatedly attaches consequences to one authority being subordinate to another — supervision, instructions and the exercise of powers by a higher authority. This section supplies the mechanism by which that hierarchy is actually declared, and leaves it to be adjusted by notification as the administration is reorganised.
Who it applies to
The Board, exercising the power to issue the notification
Any income-tax authority named in such a notification as subordinate, or as the authority to whom another is subordinate
What this means in practice
The section states no hierarchy of its own, so who is subordinate to whom in any given case is answered by the notification in force and not by the section. Nothing happens under it until a notification is issued, and the power extends to authorities in the plural on both sides, so a class of authorities can be placed under a class of superiors in one notification.
Where you meet this section
A taxpayer never meets this section directly — it produces no notice, order or form. It is relevant only indirectly, where a provision of the Act turns on whether the authority acting was subordinate to another, and the answer is found in the notification issued under this section.
The words themselves
The Board may, by notification, direct that any income-tax authority or authorities specified in the notification shall be subordinate to such other income-tax authority or authorities as specified in such notification
Section 238, Income-tax Act, 2025.
What people get wrong
Reading the section as itself laying down the ranking of income-tax authorities. It only empowers the Board to declare subordination by notification.
Assuming subordination exists by default in the absence of a notification. The section operates only through a notification specifying both the subordinate and the superior authority.
Treating the power as confined to a single authority on each side. The section speaks of an authority or authorities on both sides, so classes of authorities can be covered.
What this replaced
The correspondence is the Income Tax Department’s own, from its comparison utility for the 1961 and 2025 Acts. A renumbering is the easy half; whether the words changed is the half that decides cases.
A notification is made under a power the Act gives and, within that power, is law. These too were made under the 1961 Act and are placed here by the department’s concordance.
Notification: 15 Date of Issue: 26/2/2013 — Section 118 of the Income-tax Act, 1961 - Income-tax Authorities - Control of - CIT, Centralised Processing Cell (TDS) to BE Subor 2013-02-26
Notification No. 63/2011 — Section 118 of the Income-tax Act, 1961 - Income-tax authorities - Control of - DGIT (International Taxation) - Amendment in Notif 2011-12-30
Notification No. 44/2011 — Section 118 of the Income-tax Act, 1961 - Control of Income-tax Authorities - Notified Subordinate Officer 2011-08-26
Notification No. 73 — Section 118 of the Income-tax Act, 1961 - Control of Income-tax Authorities - Notified Subordinate Officers 2009-09-30
Notification No. 47 — Income-tax authorities specified in Column (3) of the Schedule below shall be subordinate to the Income-tax authority specified in 2008-03-27
Notification No. 286 — Income-tax authorities specified in column (3) of the Schedule below shall be subordinate to the income-tax authority specified in 2007-11-30
Notification No. 249 — Amendment of the Income-tax Rules under section 118 of the Income-tax Act, 1961 2007-09-28
Notification No. 232 — Amendment of the Income-tax Rules under section 118 of the Income-tax Act, 1961 2007-08-22
Notification No. 276 — Income tax authority specified in Column (3) of the Schedule below directed under section 118 2006-09-26
Notification No. 261 — Amendment of the Income-tax Rules under section 118 of the Income-tax Act, 1961 2006-09-14
Notification No. 260 — Amendment of the Income-tax Rules under section 118 of the Income-tax Act, 1961 2005-12-15
Notification No. 146 — Amendment of the Income-tax Rules under section 3 of the Income-tax Act, 1961 2004-05-18
Notification No. 50 — Section 118 of the Income-tax Act, 1961 - Income-tax Authorities - Control of - Notified Subordinate Officers 2003-03-12
Notification No. 229E — A notification under section 118 of the Income-tax Act, 1961 1996-03-21
What this page does not tell you. It does not reproduce the section. Everything above was written from the section’s own text as the Income Tax Department publishes it — the text is here, and nothing here is advice on your facts. Where a figure matters, read the sub-section it comes from.