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of <h1>Commissioners Can Guide ITOs in Complex Tax Matters; No Direct Quotes in Orders per Section 271(4A) & Instruction 1433.</h1> The circular addresses the scope of advice provided by Commissioners to subordinate officers in handling complex income tax matters. It clarifies that Section 271(4A) does not allow for assessments or tax levies based on agreements between assessees and Commissioners. However, in line with assurances from the Finance Minister and previous circulars, Commissioners can offer guidance to Income Tax Officers (ITOs) as per Instruction No. 1433. This guidance should be considered by ITOs when making decisions, though it should not be directly quoted in orders. Additionally, the voluntary nature of disclosures under Section 273A can be assessed based on specific queries outlined in the instruction.
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