TaxTMI 
TaxTMI 
Comparison of section 286 "Time limit for completion of assessment, reassessment and recomputation" between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)
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....ficers, Transfer Pricing Officers, and other tax authorities; it governs procedural limitation periods. Effective date or enactment date: Not stated in the document. Background & Scope Statutory hooks: Clause 286 of the Income Tax Bill, 2025; cross-references include sections 270(10), 271, 263(6), 239(3)(b), 279, 280, 166, 359, 363, 365(10), 368, 377, 378, 292, 279, 270(13), 244, 375, 269, 383, 384, 159, 274 and legacy sections 153A(2), 245HA of the Income-tax Act, 1961 (43 of 1961). Context: procedural limitation for tax proceedings. Coverage includes a table of eleven specified proceedings indicating the date from which time-limit is to be calculated and the duration allowed; additional subsections extend or suspend time-limits in desig....
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....rrangements u/s 274(1), and specifically a search/requisition-related exclusion not exceeding 180 days). Sub-sections (4)-(7) provide further extensions and remedial adjustments where excluded periods leave less than minimum operational time (e.g., extend remaining period to 60 days; extend to one year following abatement of Interim Board for Settlement proceedings u/s 245HA of the 1961 Act; extend to month-end where remaining time ends before month-end after excluding a specified period). Sub-section (8) deems certain assessments to be "made in consequence of or to give effect to" orders referred to in entry Sl. No. 8 (i.e., orders under specified sections or court orders), including cross-assessee reallocation of income, subject to opport....
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....complete the order within one year from that date, subject to exclusions. (Derived from Table Sl. No. 1.) * Example 2: Where the Assessing Officer makes a reference to the Transfer Pricing Officer u/s 166(1), the time limit prescribed for assessment/reassessment is extended by an additional twelve months. (Derived from sub-section (2).) * Example 3: If a search u/s 247 is conducted and seized items are returned after 140 days, that 140-day period is excluded from computation of the limitation (sub-section (3)(j)), and if the remaining time post-exclusion is under 60 days, the remaining period is extended to 60 days (sub-section (4)). Interplay The provision cross-refers to numerous other provisions and to the Income-tax Act, 1961 (e.g....
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....ection (3)(j)) described as "the period (not exceeding one hundred eighty days) commencing from the date on which a search is initiated u/s 247 or a requisition is made u/s 248 and ending on the date on which the seized items or the requisitioned items, are handed over..." with detailed sub-clauses (i)-(iii). Document 1 does not contain this (j) entry; instead Document 1 contains other exclusion grounds (for instance multiple items including references to section 375 declaration period) but not the explicit search/requisition clause in the same form. * Practical impact: Document 2 gives an express and time-limited exclusion for periods relating to searches/requisitions (up to 180 days), clarifying tolling in search scenarios. Its absence ....
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....rity. * Other textual differences: Document 1 contains specific additional sub-sections not present or differently worded in Document 2 - for instance Document 1 contains sub-section (6) cross-applying extension for purposes of sections 282, 287, 288 and 296 and interest u/s 437; Document 2 contains an analogous provision. * Practical impact: Largely parity, with differences focussed on the explicit search/requisition exclusion and the 153A(2) cross-reference. Practical Implications * Compliance and risk areas: The short one-year and six-month limitation windows require prompt administrative action by tax authorities; taxpayers should monitor notices/orders and potential reopening/revival triggers. The specified exclusions mean timel....