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Case lawCBDT Circulars & Instructions › CBDT Instruction No. 01/2016 - the six months in s.154(8)
CBDT Circulars & InstructionsHelps taxpayers.154s.154(8)

CBDT Instruction No. 01/2016 - the six months in s.154(8)

My rectification application has been sitting with the officer for more than six months. Has it lapsed?

My rectification application has been sitting with the officer for more than six months. Has it lapsed?

No. The Board issued this instruction precisely because officers were taking the view that an application not decided inside the six months in s.154(8) had lapsed and needed no action. The instruction records that view, rejects it, and directs that the six-month limit be strictly followed and monitored by supervisory officers.

Decided by the CBDT Circulars & Instructions (Central Board of Direct Taxes, Department of Revenue, Ministry of Finance. The instruction itself carries no signatory - its text runs 'the undersigned is directed to convey' - and the attribution to Rohit Garg, Deputy Secretary to the Government of India, comes from the commentary reproduction alone.) on 2016-02-15, reported as Instruction No. 01/2016 [F. No. 225/305/2015-ITA.II], dated 15 February 2016. It bears on section 154, section 154(8) of the Income Tax Act 1961, in Assessment & Scrutiny, Refunds, Interest & Condonation and Demand, Recovery & Stay matters.

Read this before you cite it. Both decisions that take the instruction up did so without construing it - in one the Revenue had already undertaken to dispose of the application, in the other the relief sought was limited to a direction to decide. It is authority that a court will act on the instruction to fix a timetable, not that a breach of the six months has any consequence for the application itself.
Still good law. Two Delhi High Court decisions take the instruction up by name. In L S Cable and System Ltd. v. Union of India [2020] 118 taxmann.com 469 (Delhi), Manmohan and Sanjeev Narula, JJ., W.P.(C) No. 5154 of 2020, assessment year 2017-18, decided 13 August 2020, the Court recorded at paragraph 4 the petitioner's reliance on Circular No. 14/2001 dated 9 November 2001 and on Instruction No. 01/2016, quoting its direction that the six-month time limit is to be strictly followed while disposing of applications under s.154; the Revenue then stated that the rectification application would be disposed of within six weeks and the refund processed within three weeks after that, and at paragraph 8 the Court directed exactly that, by a reasoned order and in accordance with law. In Afilias India (P.) Ltd. v. Dy. CIT [2024] 161 taxmann.com 235 (Delhi), Manmohan, Actg. CJ., and Ms. Mini Pushkarna, J., W.P.(C) Nos. 16074 and 16080 of 2023, assessment years 2017-18 and 2018-19, decided 14 December 2023, paragraph 3 records the same reliance in the same words, and at paragraph 5 the Court directed the officer to decide the rectification applications by a speaking order within eight weeks and to release the consequential refunds with up-to-date interest within a further eight weeks. Be precise about what that is. In neither case did the Court construe the instruction or hold it binding: L S Cable proceeded on the Revenue's own undertaking and Afilias on the limited relief sought. This is the instruction being cited and given effect to, not interpreted. Supersession: nothing withdrawing, superseding or replacing it was found; it carries no such annotation in a research database that does annotate superseded instruments, and a search on its file number returns only this instruction and its companion No. 02/2016 of the same date, which supplements it rather than displaces it. On currency, the six-month rule is carried into the Income-tax Act 2025 as s.287(9): "Subject to sub-section (8), an income-tax authority referred to in sub-section (1), shall pass an order for making the amendment or refusing to allow the claim within six months from the end of the month in which the application for amendment under this section is received by it from the assessee or the deductor or the collector." L S Cable and System Ltd. v. Union of India [2020] 118 taxmann.com 469 (Delhi); Afilias India (P.) Ltd. v. Dy. CIT [2024] 161 taxmann.com 235 (Delhi).

Why it matters

It is the document to quote when a rectification is simply not being dealt with, and it is more useful than the section itself, because it answers the exact excuse the officer gives - that the application has lapsed with the time limit. It also sets up an administrative escalation: the Board has told supervisory officers to monitor adherence and says administrative action may be initiated where the time frame is not kept. It works in practice: in L S Cable and System Ltd. v. Union of India [2020] 118 taxmann.com 469 (Delhi) and again in Afilias India (P.) Ltd. v. Dy. CIT [2024] 161 taxmann.com 235 (Delhi) the petitioner relied on this instruction alongside Circular No. 14/2001, and in each case the Delhi High Court directed the officer to decide the pending rectification within a fixed period and to release the consequential refund. Nothing in it says the claim is deemed allowed, so it does not do the taxpayer's work for him.

Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them.

Not yet CA-verified. This entry was found through the sources listed under the Sources tab, and the summary reflects what those sources say. Nobody has yet read the full judgment and signed it off. Check the source before relying on it.

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An intimation that disallowed two claims before anyone had answered, a rectification nobody has decided, and next year's refund goneThe processing centre disallowed my deductions and raised a demand without ever hearing me, my rectification has been sitting for seven months and my next refund has been taken against the demand - what do I do first?