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Case lawIncome-tax Rules 2026 › Rule 264
Rules 2026

Rule 264 of the Income-tax Rules, 2026

Rule 264 — Proceedings before Inquiry Officer.

Where this rule sits

← Rule 263  ·  Rule 265 →

What this rule does

The rule sets out how the Inquiry Officer conducts the inquiry.

Sub-rule (1) starts it: on receipt of the written statement of defence, or if no such statement is received within the time specified, the Inquiry Officer shall inquire into such of the charges as are not admitted. Sub-rule (2) requires him, in the course of the inquiry, to consider such documentary evidence and take such oral evidence as may be relevant or material in regard to the charges.

Sub-rule (3) gives the authorised income-tax practitioner the right to cross-examine witnesses examined in support of the charges and to give evidence in person. Sub-rule (4) requires the Inquiry Officer, if he declines to examine any witness on the ground that his evidence is not relevant or material, to record his reasons in writing.

Sub-rule (5) requires him, at the conclusion of the inquiry, to prepare a report of the inquiry recording his findings on each of the charges together with the reasons for them.

Why it is there

An inquiry into an authorised income-tax practitioner's conduct can end in consequences for his ability to practise, so the rule builds the minimum of a fair hearing into it: the inquiry proceeds only on charges not admitted, evidence on both sides is taken, the practitioner may test the case against him and give evidence himself, a refusal to hear a witness must be justified in writing, and the outcome must be a reasoned finding on each charge rather than a conclusion.

Who it applies to

What this means in practice

The scope of the inquiry is narrowed at the outset by sub-rule (1): only charges that are not admitted are inquired into, so an admission in the written statement of defence takes that charge out of the evidence-gathering stage though not out of the report, which under sub-rule (5) must record findings on each of the charges. Failing to file a written statement does not stall matters — the inquiry proceeds if none is received within the time specified. The practitioner's rights in sub-rule (3) are two and separate: to cross-examine the witnesses examined in support of the charges, and to give evidence in person. Sub-rule (4) does not stop the Inquiry Officer from refusing a witness; it requires him to record his reasons in writing when the refusal is on the ground that the evidence is not relevant or material, which is what makes the refusal examinable later. The rule takes matters as far as the report; what is done with the report is not settled here.

An example

Illustrative only, and invented for this page. The figures are chosen to show the requirement biting, not taken from any real matter.

An authorised income-tax practitioner faces three charges and admits one in his written statement of defence. The Inquiry Officer inquires into the remaining two, takes the documents and the oral evidence he considers relevant, and allows the practitioner to cross-examine the witnesses and to give evidence himself. He declines to examine one witness offered by the practitioner as not relevant, and records his reasons in writing. His report then records findings, with reasons, on each of the three charges.

Where you meet this rule

You meet it in disciplinary proceedings against an authorised income-tax practitioner, from the written statement of defence through the hearing to the Inquiry Officer's report.

The words themselves

On receipt of the written statement of defence, or if no such statement is received within the time specified, the Inquiry Officer shall inquire into such of the charges as are not admitted.
Rule 264(1), Income-tax Rules, 2026.
The authorised income-tax practitioner shall be entitled to cross-examine witnesses examined in support of the charges and to give evidence in person.
Rule 264(3), Income-tax Rules, 2026.

What people get wrong

What this page does not tell you. It does not reproduce the rule. Everything above was written from the rule’s own text as the Income Tax Department publishes it — the text is here. A rule is subordinate legislation: it prescribes the method, the form or the period, and it cannot enlarge the charge the section imposes. Where a figure matters, read the sub-rule it comes from.