Tax Circular Clarifies Instruction No. 885: Wait for Supreme Court Ruling Before Revising Assessments; Pause Section 147 Proceedings.
The circular addresses queries from Income Tax Commissioners regarding the implementation of Board's Instruction No. 885. It advises against revising completed assessments based on the Madras High Court's decision in Carborundum & Co., suggesting that the initiative should be left to the assessees. For appeals, it recommends requesting appellate authorities to defer decisions until the Supreme Court rules on the related case. Pending assessments should continue under Instruction No. 885 until further legal opinions are received. Proceedings initiated under section 147 should be paused unless time constraints necessitate completion, in which case actions should align with the Madras High Court's decision.