Section 108 of the Central Goods and Services Tax Act, 2017 deals with the powers of the Revisional Authority. It provides a mechanism through which a higher tax authority can call for and examine the record of proceedings and revise a decision or order passed by an officer subordinate to it when the statutory conditions are satisfied.
The revision mechanism is different from an ordinary appeal. An appeal is generally initiated by an aggrieved party or by the department through the mechanism provided under Section 107, whereas revision under Section 108 gives the Revisional Authority a statutory power to examine certain decisions or orders on its own motion, on information received, or on a request from specified tax authorities.
Section 108 is part of Chapter XVIII – Appeals and Revision of the CGST Act. It is intended to provide a supervisory mechanism for correcting orders that are erroneous and prejudicial to the interest of revenue, subject to the limitations and safeguards contained in the section.
What Is Section 108 of the CGST Act?
Section 108 is titled “Powers of Revisional Authority.”
The provision allows the Revisional Authority, subject to Section 121 and the applicable rules, to call for and examine the record of proceedings.
If the authority considers that a decision or order is:
- erroneous so far as it is prejudicial to the interest of revenue;
- illegal or improper;
- based on failure to consider material facts; or
- otherwise covered by the circumstances specified in Section 108,
the Revisional Authority may take appropriate action under the section.
The section also contains restrictions on when revision can be exercised, rules concerning limitation, provisions dealing with the effect of appellate or court decisions, exclusion of certain periods from limitation, and definitions of “record” and “decision.”
Who Is the Revisional Authority?
Section 2(99) of the CGST Act defines “Revisional Authority” as an authority appointed or authorised for revision of decisions or orders under the Act.
For Central Tax, CBIC issued Notification No. 05/2020-Central Tax dated 13 January 2020, authorising specific officers to act as Revisional Authorities under Section 108.
Under that notification:
- the Principal Commissioner or Commissioner of Central Tax is authorised for decisions or orders passed by an Additional or Joint Commissioner of Central Tax; and
- the Additional or Joint Commissioner of Central Tax is authorised for decisions or orders passed by a Deputy Commissioner, Assistant Commissioner or Superintendent of Central Tax.
This creates a hierarchy under which a superior officer can exercise revisional jurisdiction over specified orders of subordinate officers.
Purpose of Revision Under Section 108
The purpose of revision is to provide a supervisory mechanism where an order passed by a subordinate officer may have resulted in an erroneous position that is prejudicial to the interest of revenue.
For example, suppose an adjudicating officer passes an order allowing a tax benefit even though a relevant statutory provision or material fact was not properly considered.
If the statutory conditions under Section 108 are satisfied, the Revisional Authority can examine the record and take appropriate action.
The revision mechanism therefore serves as a separate layer of statutory control over certain decisions and orders.
Section 108(1) – Basic Power of Revision
Section 108(1) begins by making the revisional power subject to Section 121 and the rules made under the Act.
The Revisional Authority may call for and examine the record of any proceedings:
- on its own motion;
- upon information received by it; or
- on a request from the Commissioner of State tax or Commissioner of Union territory tax, as applicable under the statutory wording.
For Central Tax, the notification issued under Section 5 read with Section 2(99) identifies the officers who exercise the revisional function.
“On His Own Motion”
The Revisional Authority does not necessarily have to wait for a taxpayer or another officer to file an application requesting revision.
Section 108(1) permits the authority to act on its own motion.
This means that if the authority comes across an order that appears to satisfy the statutory conditions for revision, it can examine the matter on its own initiative.
Revision on Information Received
The Revisional Authority may also act when information comes to its notice.
The information could arise from departmental records, audit observations, internal examination or other legally relevant sources.
However, the mere receipt of information does not automatically mean that the original order will be revised.
The authority must still examine the record and determine whether the requirements of Section 108 are satisfied.
Request From Specified Tax Authorities
Section 108(1) also permits revision on a request from the Commissioner of State tax or Commissioner of Union territory tax in the circumstances specified by the provision.
This reflects the coordination required within the GST framework because a particular decision may have implications across different tax components.
For Central Tax, the notified hierarchy under Notification No. 05/2020-Central Tax determines the relevant Revisional Authority for specified Central Tax orders.
What Kind of Order Can Be Revised?
Section 108(1) covers a decision or order passed under:
- the CGST Act;
- the applicable State GST Act; or
- the Union Territory GST Act,
by an officer subordinate to the Revisional Authority, according to the statutory framework.
For Central Tax revision, the relevant subordinate-officer hierarchy is determined through the authorisation issued by CBIC.
The provision therefore does not allow an officer to revise every GST order without regard to jurisdiction or hierarchy.
When Can an Order Be Revised?
The core requirement under Section 108 is that the Revisional Authority must consider the decision or order to be erroneous in so far as it is prejudicial to the interest of revenue, along with the statutory grounds specified in Section 108(1).
The provision refers to situations where the decision or order is:
- illegal;
- improper;
- based on failure to take into account certain material facts; or
- affected by material facts that were available at the time of issuance or became available later.
The section also covers action taken in consequence of an observation by the Comptroller and Auditor General of India (CAG).
Erroneous and Prejudicial to the Interest of Revenue
Two concepts are particularly important:
Erroneous
The order must suffer from an error recognised within the scope of Section 108.
For example, an order may incorrectly apply a statutory provision, overlook a relevant legal requirement or fail to consider relevant material.
Prejudicial to the Interest of Revenue
The error must also be prejudicial to the interest of revenue.
Therefore, Section 108 is not simply a general power to reconsider every order with which the Revisional Authority disagrees.
The statutory conditions must be satisfied before the revisional power is exercised.
Illegal or Improper Order
Section 108 expressly refers to a decision or order being illegal or improper.
An order may therefore be examined where the statutory requirements were not correctly followed or where the decision is legally unsustainable within the scope of the provision.
The Revisional Authority must examine the actual record and circumstances before taking action.
Failure to Consider Material Facts
Another important ground is that the original decision or order may not have taken into account certain material facts.
The provision is particularly significant because it states that such material facts may be facts that were:
- available at the time the order was issued; or
- not available at that time but became relevant subsequently, as covered by the statutory wording.
This means that the revision mechanism is not necessarily restricted to material that was physically present in the original file at the exact time the order was passed.
CAG Observation and Revision
Section 108(1) also refers to a situation arising from an observation by the Comptroller and Auditor General of India.
If a CAG observation identifies an issue relating to a decision or order, the Revisional Authority may examine the matter in accordance with Section 108.
The CAG observation itself does not automatically rewrite the original order. The Revisional Authority must still exercise the statutory power and follow the requirements of the Act.
Power to Stay the Operation of an Order
Section 108(1) gives the Revisional Authority the power, if necessary, to stay the operation of the decision or order.
The stay can continue for such period as the Revisional Authority considers appropriate.
This is important where immediate operation of the original order could affect revenue or otherwise interfere with the revision proceedings.
A stay is therefore a procedural tool available to the Revisional Authority; it is not the same as the final revisional order.
Opportunity of Being Heard
Before passing a revisional order that affects the concerned person, the statutory framework requires an opportunity of being heard.
Section 108(1) expressly provides that the Revisional Authority must give the person concerned an opportunity of being heard before passing the order.
Rule 109B further provides that where the Revisional Authority proposes to pass an order under Section 108 that is likely to adversely affect the person, a notice in FORM GST RVN-01 must be served and a reasonable opportunity of being heard must be given.
FORM GST RVN-01
Rule 109B provides the procedural mechanism for revision proceedings.
Where the proposed revisional order is likely to adversely affect the person, the Revisional Authority serves FORM GST RVN-01, titled a notice under Section 108.
The official form identifies the decision or order proposed to be revised and provides the grounds on which the Revisional Authority proposes to exercise revision.
The form also provides an opportunity for the person to furnish a reply and appear for a personal hearing.
Time Given in FORM GST RVN-01
The prescribed form provides for a reply within the period specified in the notice and also identifies the date and time for personal hearing.
The taxpayer or affected person should therefore carefully examine the notice and comply within the time specified.
Failure to respond or appear may result in the matter being decided on the basis of the available records and merits, as stated in the prescribed form.
Further Inquiry by Revisional Authority
Section 108(1) allows the Revisional Authority to make such further inquiry as may be necessary.
The authority is therefore not restricted to simply accepting the information that initially brought the matter to its attention.
It can examine the record, consider the response of the affected person and conduct further inquiry required for deciding whether revision is justified.
What Orders Can the Revisional Authority Pass?
After examining the matter and following the required procedure, the Revisional Authority may pass an order that it considers just and proper.
Section 108(1) specifically mentions the power to:
- enhance the original decision or order;
- modify the original decision or order; or
- annul the original decision or order.
The precise relief or change depends on the facts and legal circumstances of the case.
Enhancement of an Order
The Revisional Authority may enhance the consequences of the original decision or order where the statutory requirements are satisfied.
For example, if an order incorrectly determined a lower amount payable to the Government and the matter falls within the revisional jurisdiction, the authority may modify the order in a manner that increases the amount payable.
However, the affected person must receive the procedural safeguards applicable to the revision proceedings.
Modification of an Order
The Revisional Authority may also modify the original order.
Modification does not necessarily mean that the entire order will be cancelled.
The authority may alter a particular finding, calculation, tax treatment or other part of the decision, depending on the issue requiring revision.
Annulment of an Order
The Revisional Authority may also annul the original decision or order where the statutory circumstances justify such action.
Annulment means that the original order is set aside through the revisional mechanism.
The consequences will depend on the nature of the original order and the directions contained in the revisional order.
Section 108(2) – When Revision Cannot Be Exercised
Section 108(2) contains important restrictions on the power of revision.
The Revisional Authority cannot exercise the power under Section 108(1) in specified situations.
These restrictions are important because revision is not intended to create an unlimited parallel appeal mechanism.
Revision Bar When Order Has Already Been Appealed
Under Section 108(2)(a), revision cannot generally be exercised if the order has been subject to an appeal under:
- Section 107;
- Section 112;
- Section 117; or
- Section 118.
This prevents the same order from being simultaneously pursued through multiple statutory routes in circumstances where the Act bars revision.
Revision Bar During the Departmental Appeal Period
Section 108(2)(b) provides that the Revisional Authority cannot exercise the power where the period specified under Section 107(2) has not yet expired.
This is important because the department has a statutory period for filing an appeal under Section 107(2).
The revisional mechanism is therefore restricted while that statutory departmental appeal period remains open.
Three-Year Limitation
Section 108(2)(b) also provides that revision cannot be exercised where more than three years have expired after the passing of the decision or order sought to be revised.
Thus, the normal outer period under Section 108(2)(b) is three years from the passing of the decision or order, subject to the specific statutory exclusions and provisos contained in Section 108.
Example
Suppose an order was passed on 10 January 2024.
The three-year period under Section 108(2)(b), subject to applicable exclusions and the specific statutory framework, would ordinarily run with reference to that order.
The Revisional Authority cannot simply initiate revision after the statutory period has expired.
Revision Already Taken Up Earlier
Section 108(2)(c) prevents the Revisional Authority from exercising the power where the order has already been taken for revision under Section 108 at an earlier stage.
This prevents repeated revisional proceedings against the same order through the same statutory mechanism.
Revision of a Revision Order
Section 108(2)(d) provides that revision cannot be exercised where the order itself was passed in exercise of the powers under Section 108(1).
In simple terms, a revisional order cannot ordinarily be subjected to another round of revision under the same provision.
Further remedies are available through the appellate structure specified in the Act.
Proviso to Section 108(2)
There is an important proviso to Section 108(2).
Where an order has been subject to an appeal, the Revisional Authority may still pass an order under Section 108(1) on a point that has not been raised and decided in that appeal.
This must be done:
- before the expiry of one year from the date of the order in the appeal; or
- before the expiry of three years referred to in Section 108(2)(b),
whichever is later.
This prevents an issue that was never examined in the appeal from automatically escaping revisional scrutiny merely because another issue was decided in the appeal.
Example of the Proviso
Suppose an original order contains Issues A and B.
The taxpayer appeals, but the appeal only raises Issue A.
The Appellate Authority decides Issue A.
If Issue B was neither raised nor decided in the appeal, the proviso to Section 108(2) can permit the Revisional Authority to examine Issue B, subject to the statutory time requirements.
This does not mean that the entire original order can be reopened without limitation. The statutory condition specifically concerns a point that was not raised and decided in the appeal.
Section 108(3) – Finality of Revision Order
Section 108(3) provides that every order passed in revision under Section 108(1) is final and binding on the parties, subject to the further appellate provisions under:
- Section 113;
- Section 117; and
- Section 118.
Therefore, “final and binding” does not mean that no further legal remedy exists.
The Act itself preserves the subsequent appellate routes.
Appeal Against a Revisional Order
A person affected by a revisional order may have further statutory remedies depending on the nature of the order and the applicable appellate provision.
Section 108(3) specifically makes the revisional order subject to Sections 113, 117 and 118.
These provisions relate to subsequent appellate stages under the GST framework.
Therefore, a Section 108 order should not be treated as an absolute end to every possible legal remedy.
Section 108(4) – Exclusion of Certain Periods
Section 108(4) deals with a situation where the decision or order under consideration involves an issue on which the Appellate Tribunal or High Court has given a decision in another proceeding, and an appeal against that decision is pending before the High Court or Supreme Court.
In such a situation, the specified period between the relevant judicial decisions is excluded while calculating the limitation under Section 108(2)(b), provided revision proceedings have been initiated by issuing a notice under Section 108.
How Section 108(4) Works
The provision covers two possible stages:
Tribunal to High Court
The period between:
- the date of the Appellate Tribunal’s decision; and
- the date of the High Court’s decision
can be excluded where the statutory conditions are satisfied.
High Court to Supreme Court
Similarly, the period between:
- the date of the High Court’s decision; and
- the date of the Supreme Court’s decision
can be excluded.
This provision is relevant where the issue involved in the revision proceedings is connected with another matter that is being litigated before a higher court.
Why Section 108(4) Is Important
The purpose of the exclusion is to prevent the statutory revision period from running in a manner that could defeat the revisional mechanism while an important identical or connected legal issue is being litigated before a higher forum.
However, the statutory conditions must be satisfied, including the requirement relating to initiation of revision proceedings by issuance of a notice under Section 108.
Section 108(5) – Stay Period Excluded
Section 108(5) provides another limitation-period protection.
Where the issuance of an order under Section 108(1) is stayed by an order of a court or Appellate Tribunal, the period of that stay is excluded while computing the limitation period referred to in Section 108(2)(b).
Example
Suppose revision proceedings are within the statutory period, but a court stays the issuance of the revisional order for a specified period.
That period of stay is excluded when calculating the relevant three-year limitation under Section 108(2)(b), subject to the statutory requirements.
Section 108(6) – Meaning of “Record”
Section 108(6) provides that, for the purposes of the section, “record” includes all records relating to any proceedings under the CGST Act that are available at the time of examination by the Revisional Authority.
This is important because the Revisional Authority is not necessarily limited to the documents that were physically available in the original adjudication file.
The statutory definition allows the authority to consider records available at the time it undertakes the examination.
Section 108(6) – Meaning of “Decision”
Section 108(6) also provides that “decision” includes an intimation given by any officer lower in rank than the Revisional Authority.
This expands the meaning of “decision” for the purpose of the revisional provision.
Therefore, the section should not be interpreted as applying only to formally titled adjudication orders where the statutory definition brings an intimation within its scope.
Rule 109B – Procedure for Revision
Section 108 should be read with Rule 109B of the CGST Rules, 2017.
Rule 109B provides that where the Revisional Authority decides to pass an order under Section 108 that is likely to adversely affect the person concerned, the authority must:
- serve notice in FORM GST RVN-01; and
- give the person a reasonable opportunity of being heard.
After passing the revisional order, the Revisional Authority must also issue a summary of the order in FORM GST APL-04, clearly indicating the final amount of demand confirmed.
FORM GST RVN-01 – Notice Under Section 108
FORM GST RVN-01 is specifically prescribed for revision proceedings.
The form identifies:
- the person concerned;
- GSTIN;
- original order number and date;
- officer who passed the original decision;
- grounds for proposed revision;
- response requirements; and
- personal hearing details.
The prescribed form also states that if the person fails to furnish a reply or fails to appear for the scheduled hearing, the case may be decided ex parte on the basis of available records and merits.
FORM GST APL-04 in Revision Proceedings
Rule 109B(2) requires the Revisional Authority to issue a summary of the revision order in FORM GST APL-04 along with the order under Section 108(1).
The summary indicates the final amount of demand confirmed.
APL-04 is therefore not limited to orders passed by the Appellate Authority; Rule 109B specifically includes the revisional order within its scope.
Who Can Be Affected by Section 108 Revision?
A taxpayer or other person whose decision or order is being revised may be affected by the proceedings.
The person may receive a Section 108 notice where the proposed revision is likely to adversely affect them.
The person should carefully review:
- the original order;
- the grounds stated in RVN-01;
- the documents relied upon;
- the legal provisions mentioned;
- the proposed changes;
- the limitation position; and
- the hearing date.
Practical Example – Incorrect Tax Determination
Suppose an adjudicating officer determines GST liability at ₹5 lakh.
Later, the Revisional Authority examines the record and finds that a material provision was not considered and that the decision is erroneous and prejudicial to revenue.
If all conditions under Section 108 are satisfied, the Revisional Authority may initiate revision and, after giving the affected person an opportunity of hearing, pass an appropriate order.
Depending on the circumstances, the original order may be modified or enhanced.
Practical Example – Order Ignoring Material Facts
Suppose a taxpayer’s transaction involves a contractual condition that materially affects the tax treatment.
The adjudicating authority passes an order without considering that material fact.
If the order is prejudicial to revenue and falls within the grounds specified in Section 108, the Revisional Authority may examine the record and consider revision.
The taxpayer must receive the prescribed opportunity to respond before an adverse revisional order is passed.
Practical Example – Order Already Appealed
Suppose an adjudicating authority passes an order and the taxpayer files an appeal under Section 107.
Once the order has been subject to appeal, Section 108(2)(a) restricts the Revisional Authority from exercising revisional power over that order, subject to the specific proviso dealing with points not raised and decided in the appeal.
This prevents overlapping proceedings while preserving the statutory treatment of issues that were not considered in the appeal.
Practical Example – Three-Year Limitation
Suppose an order is passed on 1 April 2024.
Ordinarily, more than three years after the order would fall outside the limitation mentioned in Section 108(2)(b), subject to the specific exclusions and provisos provided in Section 108.
Therefore, the department cannot treat Section 108 as an unlimited power to reopen old orders.
Revision vs Appeal Under Section 107
Section 108 revision and Section 107 appeal are different mechanisms.
| Basis | Section 107 | Section 108 |
|---|---|---|
| Main mechanism | Appeal | Revision |
| Typical initiating party | Aggrieved person or department through statutory mechanism | Revisional Authority |
| Authority | Appellate Authority | Revisional Authority |
| Nature | Appellate remedy | Supervisory revisional power |
| Main focus | Challenge to decision/order | Examination of erroneous and revenue-prejudicial order |
| Limitation | Governed by Section 107 | Governed by Section 108 |
| Further remedy | Further appellate provisions | Sections 113, 117 and 118, as applicable |
The two mechanisms should therefore not be treated as interchangeable.
Revision vs Review
The words review and revision are sometimes used informally as if they mean the same thing, but the CGST Act distinguishes the statutory mechanisms.
Section 107 contains provisions dealing with departmental review and appeal.
Section 108 specifically provides the revisional mechanism.
The Revisional Authority acts under the statutory conditions of Section 108 and does not have an unrestricted power to reconsider every order simply because another view is possible.
Why Section 121 Matters
Section 108(1) begins with the words “Subject to the provisions of section 121 and any rules made thereunder.”
Section 121 contains provisions concerning certain decisions and orders that are not subject to revision.
Therefore, Section 108 must always be read together with Section 121.
The Revisional Authority cannot exercise Section 108 power where the Act expressly places a decision or order outside the revision mechanism.
Importance of Limitation Under Section 108
Limitation is one of the most important practical aspects of revision.
The key rules include:
- revision cannot generally be exercised while the departmental appeal period under Section 107(2) remains open;
- revision cannot generally be exercised after three years from the passing of the decision or order;
- specific provisions allow revision on an issue not raised and decided in an appeal within the period specified by the proviso;
- certain periods may be excluded under Sections 108(4) and 108(5).
Therefore, the limitation calculation should be examined carefully in every Section 108 proceeding.
What Should a Taxpayer Do After Receiving RVN-01?
A taxpayer receiving FORM GST RVN-01 should:
- Check the original order.
- Read every ground stated in the revision notice.
- Check whether the Revisional Authority has jurisdiction.
- Verify the limitation period.
- Check whether the original order has already been appealed.
- Identify the exact issue proposed for revision.
- Collect supporting documents.
- Prepare a point-by-point reply.
- Attend the personal hearing where required.
- Preserve proof of submission.
- Review the consequences of the proposed enhancement or modification.
- Seek professional legal or tax advice where the matter involves substantial liability.
Important Points to Remember About Section 108
Section 108 can be summarised as follows:
- Section 108 deals with the powers of the Revisional Authority.
- The Revisional Authority can call for and examine records of proceedings within its statutory jurisdiction.
- Revision can be initiated on the authority’s own motion.
- It can also be initiated on information received by the authority.
- The provision also recognises requests from specified tax authorities.
- The decision or order must satisfy the statutory conditions for revision.
- The order must be erroneous in a manner prejudicial to the interest of revenue.
- The provision covers orders that are illegal or improper.
- It also covers failure to consider certain material facts.
- The section refers to material facts whether available at the time of the original order or not.
- CAG observations can also be relevant to revision.
- The Revisional Authority may stay the operation of the original order where necessary.
- The affected person must be given an opportunity of being heard.
- The authority may make further inquiry.
- The authority may enhance, modify or annul the original decision or order.
- Revision is restricted where the order has already been subject to specified appeals.
- Revision cannot generally be exercised while the departmental appeal period under Section 107(2) has not expired.
- More than three years after the passing of the order is generally outside the limitation under Section 108(2)(b), subject to statutory exclusions and the proviso.
- An order already taken up for revision cannot ordinarily be revised again under Section 108.
- An order passed under Section 108(1) cannot ordinarily be subjected to another revision under the same provision.
- The proviso to Section 108(2) permits revision on a point not raised and decided in an appeal, subject to the specified time limits.
- A revisional order is final and binding subject to the further appellate provisions specified in the Act.
- Section 108(4) excludes specified periods connected with appeals before the High Court or Supreme Court from the revision limitation calculation.
- Section 108(5) excludes the period during which issuance of the revision order is stayed by a court or Appellate Tribunal.
- “Record” has a specific meaning under Section 108(6).
- “Decision” includes specified intimations for the purpose of Section 108.
- Rule 109B prescribes the notice and procedural mechanism for adverse revision proceedings.
- FORM GST RVN-01 is the notice used for Section 108 revision proceedings.
- FORM GST APL-04 is issued as a summary of the final demand confirmed in the revisional order.
👉 Read More → Section 109 – Constitution of Appellate Tribunal and Benches thereof
Conclusion
Section 108 of the CGST Act provides an important revisional mechanism under GST. It enables the Revisional Authority to examine certain decisions and orders passed by subordinate officers where the statutory requirements for revision are satisfied.
The provision is primarily concerned with orders that are erroneous in a manner prejudicial to the interest of revenue and also refers to decisions or orders that are illegal, improper or affected by failure to consider material facts. The Revisional Authority may act on its own motion, on information received or through the other statutory routes specified in Section 108.
The powers available under Section 108 are substantial. After following the prescribed procedure, including giving the affected person an opportunity of being heard, the Revisional Authority may enhance, modify or annul the original decision or order. Where an adverse revisional order is proposed, Rule 109B requires notice in FORM GST RVN-01 and a reasonable opportunity of hearing.
At the same time, Section 108 places important restrictions on revisional power. Revision cannot ordinarily be exercised where the order has already been subject to the specified appeal proceedings, while the departmental appeal period under Section 107(2) remains open, after the prescribed three-year period, or where the order has already been taken up for revision. The proviso to Section 108(2) provides a specific mechanism for dealing with points that were not raised and decided in an appeal.
The section also contains special rules for limitation. Section 108(4) excludes specified periods during which related appellate proceedings are pending before higher courts, while Section 108(5) excludes the period during which issuance of the revisional order is stayed by a court or Appellate Tribunal. These provisions are important when calculating whether revision remains legally available.
For Central Tax, Notification No. 05/2020-Central Tax authorises the Principal Commissioner or Commissioner of Central Tax to act as Revisional Authority for specified orders passed by Additional or Joint Commissioners, and the Additional or Joint Commissioner for specified orders passed by Deputy Commissioners, Assistant Commissioners or Superintendents.
In practical terms, Section 108 should not be understood as an unlimited power to reopen GST orders. It is a structured statutory revision mechanism with defined grounds, jurisdictional requirements, limitation periods, procedural safeguards and further appellate remedies.
A taxpayer receiving a Section 108 revision notice should therefore examine the original order, the grounds of revision, the authority exercising the power, the limitation period, any previous appeal or revision proceedings and the supporting records before submitting a detailed response.
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