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<h1>Late Income Tax Returns: Filing Under Section 139(4) and Its Validity After Best Judgment Assessment Cancellation</h1> Under Section 139(4) of the Income Tax Act, if a return is not filed within the prescribed time under Section 139(1) or a notice under Section 142(1), it can be filed before the assessment is completed, or three months before the end of the assessment year, whichever is earlier. Assessment completion refers to the date the assessment order is passed, not when it is served. A return filed after the assessment but before the demand notice is invalid. However, if a return is filed after a best judgment assessment is canceled, it is considered filed under Section 139(4).