Section 264 Revision - ₹10,740 Refund Ordered by PCIT Hyderabad
Section 264 Revision - ₹10,740 Refund Ordered by PCIT Hyderabad
Notice Type
Revision Application - Section 264 / Rectification — Section 154
Category
Tax Notices for Individuals
Outcome
PCIT Hyderabad-1 directed AO to pass a fresh Section 154 order crediting ₹28,300 already paid. Refund of ₹10,740 ordered in taxpayer's favour.
The Situation
An individual taxpayer in Hyderabad paid a tax demand of ₹28,300 for AY 2020-21 in full, but when CPC passed a subsequent Section 154 rectification order reducing the demand to ₹17,560, it failed to credit the payment already made. A Section 264 revision application was filed before PCIT Hyderabad-1 to recover the resulting refund of ₹10,740.
Our Approach
You paid the tax demand in full. CPC still didn't credit your payment. Here's how we got the refund ordered.
The Problem
An individual taxpayer filed and revised his return for AY 2020-21. CPC processed the revised return under Section 143(1) and raised a demand of ₹28,300, which the taxpayer paid immediately.
Shortly after, CPC passed a rectification order under Section 154 reducing the demand to ₹17,560. That should have triggered a refund of ₹10,740. Instead, CPC's own Section 154 order failed to credit the ₹28,300 already paid — and no refund was processed.
Filing another rectification request with CPC would have sent the matter back to the same system that caused the problem. The correct remedy was a revision application before the Principal Commissioner under Section 264 - a superior authority with the power to direct a correction.
What We Did
Choosing Section 264 Over Another Section 154 Request Section 154 had already been invoked and the resulting order was the source of the error. A fresh rectification request with CPC would loop back to the same outcome. We filed directly before PCIT Hyderabad-1 under Section 264, which bypasses CPC and puts the matter before an authority that can direct the correction.
Establishing the Error With Form 26AS The tax payment was fully reflected in Form 26AS. We placed that entry alongside CPC's Section 154 order to show the PCIT exactly where the credit had been omitted. No complex arguments were needed - the two documents together made the omission self-evident.
Appearing Before PCIT and Securing the Direction At the personal hearing before PCIT Hyderabad-1, we presented submissions and the supporting documents. The PCIT confirmed the omission and directed the Assessing Officer to pass a fresh Section 154 order crediting the full payment and releasing the refund.
The Result
PCIT Hyderabad-1 allowed the Section 264 application and directed the AO to credit the ₹28,300 payment already made. Refund of ₹10,740 ordered in the taxpayer's favour.
Key Takeaway: If CPC's Section 154 order misses crediting a payment you have already made, do not file another rectification with CPC. A Section 264 revision before the Principal Commissioner is the right remedy - and if your payment is visible in Form 26AS, that single document is enough to establish the error and get the refund directed.
Result
PCIT Hyderabad-1 directed AO to pass a fresh Section 154 order crediting ₹28,300 already paid. Refund of ₹10,740 ordered in taxpayer's favour.
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