Comparison of section 282 "Time limit for notices u/ss 280 and 281." between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

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....fects taxpayers, assessing officers and the Department; effective/decision date: Not stated in the document. Background & Scope Statutory hooks: references within the text are to sections 280 and 281 of the same enactment (Procedure for assessment). The provision governs temporal jurisdiction to issue notices where income is alleged to have escaped assessment. Definitions: the text does not supply definitions (for example, of "relevant tax year", "books of account", "other documents", "income chargeable to tax which has escaped assessment" or "Assessing Officer"). Not stated in the document. Scope: applies to notices u/ss 280 (notice to assess) and 281 (notice to show cause) for the relevant tax year; sets both outer and inner temporal cu....

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....eks to balance finality for taxpayers with the Department's interest in pursuing substantial cases of escaped income. The four-year rule (and four-year rule with three months for section 280) provides a general limitation period; the extension to six years is conditional on the presence of evidence or information indicating significant escaped income (threshold: fifty lakh rupees). The separate one-year bar suggests a cooling-off or administrative window during which notices cannot be issued, possibly to allow other processes (filing, assessment) to conclude; however, the document does not explain the policy reasons. Not stated in the document. Exceptions/Provisos The text contains two express exceptions/provisos: * For section 280 ....

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....ther provisions: the text refers to sections 280 and 281. The clause differentiates tests for extension between those two sections: possession of documentary evidence is expressly required for section 280 extension, whereas for section 281 an information-based standard suffices. The provision does not reference any Rules, Notifications or Circulars. Not stated in the document: any linkage to penalty provisions, prosecution timelines, or assessment/revision provisions; nor any transitional or retrospective application rules. Practical Implications * Compliance and risk areas: Taxpayers should note that general finality arises at four years (or four years and three months for section 280), but the Department can reopen or issue notices up ....

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....1 can be issued within one year from the end of any tax year. * The text does not define key terms, explain thresholds' rationale, describe evidentiary standards, or state effective date or transitional rules. Not stated in the document. Differences between the Two Versions and Practical Impact Topic Clause 282 (Bill, Old Version) Section 282 (Income-tax Act, 2025) Practical Impact Form/Source Presented as Clause 282 of the Income Tax Bill, 2025 (Old Version); accompanied by a brief explanatory line: "Clause 282 of the Bill provides for time limit for notices..." Presented as Section 282 of the Income-tax Act, 2025 (enacted text). Substantive wording largely identical; enactment confirms legislative finality. The expl....