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of <h1>Circular Limits Reopening of Finalized Assessments Before April 1, 2001, u/s 147 Due to Section 14A Provisions.</h1> The circular addresses the restriction on reopening completed assessments due to the provisions of section 14A of the Income-tax Act, 1961. Section 14A, introduced retrospectively, disallows deductions for expenditures related to income not included in total income. The Finance Act, 2001, clarified that such expenditures cannot offset taxable income. The Board has observed instances of reopening finalized assessments after the insertion of section 14A, which could lead to taxpayer hardship and unnecessary litigation. Consequently, it directs that assessments finalized before April 1, 2001, should not be reopened under section 147 to disallow expenditures for exempt income.
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