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of <h1>Section 144B Applies to Section 147 Assessments: Draft Orders Required for Significant Variations, Overrides Tribunal Decisions.</h1> The circular addresses the applicability of Section 144B of the Income Tax Act, 1961, to assessments or reassessments under Section 147. It clarifies that the provisions of Section 144B, which include a non-obstante clause, apply to such assessments, contrary to certain tribunal and appellate decisions. The Ministry of Law advises that assessments under Section 147 should be treated as assessments under Section 144B, necessitating the forwarding of a draft assessment order to the assessee if variations exceed a specified amount. The Board instructs that references to the Inspecting Assistant Commissioner (IAC) should be timely to avoid assessments being barred by limitation.
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