Loading...

⚠ ✕
❮ Top
☎ Help
☰
×

By creating an account you can:

Logo TaxTMI
Call Us / Help / Feedback✕

Contact Us At :

✉ E-mail: [email protected]

✆ Call / WhatsApp at: +91 99117 96707

For more information, Check Contact Us

FAQs :

To know Frequently Asked Questions, Check FAQs

Most Asked Video Tutorials :

For more tutorials, Check Video Tutorials

Submit Feedback/Suggestion :

Email :
Please provide your email address so we can follow up on your feedback.
Category :
Description :
Min 15 characters 0/2000
Make Most of Text Search ✕
  1. Checkout this video tutorial: How to search effectively on TaxTMI.
  2. Put words in double quotes for exact word search, eg: "income tax"
  3. Avoid noise words such as : 'and, of, the, a'
  4. Sort by Relevance to get the most relevant document.
  5. Press Enter to add multiple terms/multiple phrases, and then click on Search to Search.
  6. Text Search
  7. The system will try to fetch results that contains ALL your words.
  8. Once you add keywords, you'll see a new 'Search In' filter that makes your results even more precise.
  9. Text Search
╳
Add to...
You have not created any category. Kindly create one to bookmark this item!
✕
Create New Category
Hide
Title :
Description :
❮❮ Hide
❮ Default View
Expand ❯❯
Close ✕
🔎 Filters / Advanced Search ❯
TEXT

Press 'Enter' to add multiple search terms. Rules for Better Search

Search In
Main Text + AI Text ❯
  • Main Text
  • Main Text + AI Text
  • AI Text
Law:
---- All Laws---- ❯
  • ---- All Laws----
  • Benami Property
  • Bill
  • Central Excise
  • Companies Law
  • Customs
  • DGFT
  • FEMA
  • GST
  • GST - States
  • IBC
  • Income Tax
  • Indian Laws
  • Money Laundering
  • SEBI
  • SEZ
  • Service Tax
  • VAT / Sales Tax
Types:
---- All Types ---- ❯
  • ---- All Types ----
  • Act Rules
  • Case Laws
  • Circulars
  • Manuals
  • News
  • Notifications
Sort By: ?
In Sort By 'Default', exact matches for text search are shown at the top, followed by the remaining results in their regular order.
Relevance Default Date
    Case Laws Income Tax
    Navigating the Faceless Assessment Regime: A Judicial Perspective
    Case Laws Income Tax
    Evidentiary Value of Statements Recorded During Income Tax Surveys: A Judicial Analysis
    Case Laws Income Tax
    Faceless Assessment: Ensuring Compliance with Statutory Provisions
    Case Laws Income Tax
    Faceless Assessment Mechanism: Jurisdictional Limits in Income Tax Proceedings
    Case Laws Income Tax
    Reassessment Notices for AY 2013-14: Upholding the Doctrine of Limitation
    Case Laws Income Tax
    Decoding the Mandatory Timelines: A Thorough Examination of the Income Tax Assessment Order Nullific...
    Case Laws Income Tax
    Stay of Tax Demand: Interpreting the Discretionary Power u/s 220(6) of the Income Tax Act
    Case Laws Income Tax
    Interpreting "Technical Services" under Tax Treaties: A Comprehensive Analysis
    Case Laws Income Tax
    Navigating the Registration Process u/s 80G: Insights from the ITAT Ruling
    Case Laws Income Tax
    Ensuring Fair Proceedings: The Importance of Proper Notice Service in Income Tax Matters
    Case Laws Income Tax
    Unraveling the Royalty Conundrum and DTAA: ITAT's Stance on Marketing and Reservation Fees
    Case Laws Income Tax
    Royalty or Not? Decoding the Taxability of Marketing and Reservation Contributions under India-USA D...
    Case Laws Income Tax
    Unraveling the Intricacies: Assessing a Political Party's Claim for Income Tax Exemption
    Case Laws Income Tax
    Bogus Capital Gains and Accommodation Entries: Unraveling the Penny Stock Scam and Tax Evasion
    Case Laws Income Tax
    Strict Interpretation of Exemption Provisions: Supreme Court's Ruling on Section 10B(8) of the Incom...
    Case Laws Income Tax
    Disallowance u/s 14A: Prospective or Retrospective Effect of the Amendment?
    Case Laws Income Tax
    Navigating the Complexities of "Charitable Purpose" in Income Tax Exemptions
    Case Laws Income Tax
    Cooperative Banks vs. Primary Agricultural Credit Societies: Implications for Section 80P Deduction
    Case Laws Income Tax
    Exemption u/s 11: Condonation of Delay in Filing Form 10
    Case Laws Income Tax
    Interpreting Section 249(4)(b) of the Income Tax Act: When Non-Payment of Advance Tax Cannot Dismiss...
❮
❯
❯❯
Maximize Maximize Maximize
0 / 200
Expand Note
Add to Folder

No Folders have been created

+

Are you sure you want to delete "My most important" ?

NOTE:

Notes
Showing Results for :
Reset Filters
Results Found:
Show All Summaries Hide All Summaries
Case Laws Income Tax
Show AI Summary
Faceless assessment mechanism requires reassessment steps to follow a centralized faceless procedure, otherwise territorial officer lacks jurisdiction.
The Scheme framed under the enabling provision must be read to include preliminary proceedings linked to reassessment, so that reassessment initiation and related steps follow the faceless mechanism; concurrent exercise of territorial and faceless functions would undermine the Scheme's purpose and render steps taken outside the faceless protocol inconsistent with the statutory framework.
Case Laws Income Tax
Show AI Summary
Evidentiary value of survey statements: survey disclosures lack conclusive weight and require independent corroboration.
Statements recorded during a tax survey are permissive and not taken on oath, so they are not conclusive evidence by themselves; they cannot be treated as inherently incriminating material to justify reopening assessments or making additions without independent corroboration, and must be recorded free of coercion in line with administrative instructions and judicial precedents.
Case Laws Income Tax
Show AI Summary
Faceless assessment jurisdiction: JAO lacked authority under the statutory faceless procedure, invalidating improperly issued notices.
The court determined that reassessment notices and related proceedings were inconsistent with the statutory faceless assessment framework because they were issued without following the prescribed allocation of jurisdiction and procedural sequence under the faceless mechanism; administrative orders purportedly exempting cases were not read to displace the statutory requirements and earlier precedent interpreting the faceless provisions was applied.
Case Laws Income Tax
Show AI Summary
Faceless Assessment: statutory scheme governs jurisdiction and extends to central and international taxation proceedings.
The court analysed Section 151A read with Sections 144B and 148A and held that administrative instructions dated March 31, 2021 and September 6, 2021 issued under section 119 apply only to assessment orders and do not extend to proceedings under Sections 148A and 148; those instructions cannot be read into the scheme notified on March 29, 2022. The mandatory faceless procedure under Sections 144B and 151A applies to notices and proceedings, including central charges and international taxation charges, and notices issued outside that mechanism fall outside the statutory jurisdictional framework.
Case Laws Income Tax
Show AI Summary
Doctrine of limitation prevents revival of lapsed reassessment powers; administrative instructions cannot "travel back in time."
The court held that when the right to reopen assessment had already lapsed under the pre amended limitation regime, subsequent amendments or administrative instructions could not revive that right; administrative attempts to "travel back in time" and extend limitation were invalid, assessees retain the defence of limitation, and pandemic era notifications did not cover years whose limitation had already expired.
Case Laws Income Tax
Show AI Summary
Mandatory timelines under Section 144C require assessments to be completed within the prescribed month after DRP direction, else invalid.
Once the DRP framed directions, the Assessing Officer was obliged to complete the assessment in conformity with those directions within one month from the end of the month in which the DRP's direction was served; service by uploading the DRP directive on the ITBA portal constitutes valid service for computing that period. The procedure does not envisage further involvement of the Transfer Pricing Officer once the DRP's direction is issued and an order under the transfer pricing provision has been remitted to the AO.
Case Laws Income Tax
Show AI Summary
Assessing Officer discretion in granting stay of tax demand cannot be rigidly constrained by administrative OMs, requiring case specific consideration.
The Assessing Officer's discretionary power under section 220(6) to grant stay of tax demand is not fettered by CBDT Office Memorandums; those OMs are administrative guidelines and do not mandate a uniform pre deposit. The AO must consider prima facie case, likelihood of success, and undue hardship and may require a higher, lower or no deposit depending on case specific facts. Administrative adjustment of refunds without considering a pending stay application was held arbitrary and the matter was remitted for reconsideration applying these principles.
Case Laws Income Tax
Show AI Summary
Technical services interpretation requires specialized expertise and a demonstrable link to payments for withholding tax consequences.
Interpretation of technical services under the India Ireland DTAA requires the application or transfer of specialized knowledge, skill or expertise; incidental training or assistance enabling a reseller to market standard software does not meet that threshold. The Reseller Agreement did not contemplate technology transfer or bespoke solutions, payments were tied to reseller net revenue, and the record lacked material linking remittances to customized technical services. Authorities must establish an evidentiary and contractual nexus between payments and provision of specialized technical services before applying withholding tax under the treaty.
Case Laws Income Tax
Show AI Summary
Section 80G registration: provisional approval permits subsequent final registration, with commencement dated from provisional grant.
The tribunal construed the proviso-based registration mechanism to permit institutions granted provisional approval to apply for final registration, counting the date of commencement of activities from the grant of provisional approval; administrative circulars extending renewal deadlines apply to specified renewal applications and do not curtail the availability of final registration for provisionally approved institutions, while a view excluding applicants who commenced activities prior to provisional approval was considered inconsistent with the proviso scheme.
Case Laws Income Tax
Show AI Summary
Proper service of notice: portal-only publication cannot substitute direct communication and mandates a fresh hearing.
Proper service of notice in income tax proceedings is essential to safeguard the right to be heard and facets of natural justice. Placing notices on an electronic portal without direct communication does not, by itself, satisfy statutory methods of service, and cannot be presumed to give the taxpayer effective notice. Where service in terms of the Act and Rules is not shown, affected parties are entitled to a fair opportunity to file replies and be heard, and the tax administration must provide a fresh hearing and issue an independent speaking order after considering the reply.
Case Laws Income Tax
Show AI Summary
Taxability of marketing contributions: non taxable where receipts are fiduciary and subject to mutuality, not royalty.
Where receipts from hotels are received with a corresponding obligation to expend them for agreed common purposes and are held in a fiduciary capacity, such marketing contributions, reward program receipts, reservation contributions and central reservation system fees are not consideration for use of intellectual property or fees for technical services and thus do not qualify as royalty or fees for included services under the India-US DTAA, particularly in the absence of a permanent establishment and where coordinate precedent on identical facts supports non taxability under the principle of mutuality.
Case Laws Income Tax
Show AI Summary
Royalty characterization: marketing and reservation contributions treated as non-royalty under DTAA when tied to agreed-use obligations.
Whether marketing and reservation contributions from Indian hotels to a US company qualify as Royalty or Fees for Included Services under the India-USA DTAA turns on their substantive nature: the presence of a corresponding contractual obligation to apply funds for agreed marketing, advertising and reservation activities and supporting auditor evidence indicates such receipts are not consideration for making available intellectual property or technical services, distinguishing them from factual scenarios where contributions increase brand value or transfer intangible know how.
Case Laws Income Tax
Show AI Summary
Section 13A compliance: failure to meet proviso conditions bars political party exemption and informs stay assessment approach.
A registered political party's claim of exemption under Section 13A was rejected for failure to meet proviso conditions, including receipt of donations in breach of the cash donation prohibition; the tribunal treated non exempt voluntary contributions as income from other sources, disallowing deductions; allegations of mala fides were dismissed due to the party's procedural delays; and the tribunal's prima facie framework for stay applications-assessing merits, undue hardship, and likelihood of success-was upheld, with liberty to apply afresh to the tribunal given changed circumstances.
Case Laws Income Tax
Show AI Summary
Burden of Proof under section sixty eight: genuineness of share transactions must be established or treated as accommodation entries.
The dispute concerned alleged bogus long term capital gains from penny stock trading characterised as an accommodation entry; revenue contested genuineness, identity and creditworthiness of parties while assessees relied on expert and market information. Applying the doctrine of preponderance of probabilities, the court reiterated that the initial burden to prove identity and genuineness lies with the assessee, criticised inadequate enquiries by authorities, rejected expert and media reliance as a substitute for due diligence, and described the accommodation entry modus operandi leading to findings that the transactions were not satisfactorily proved.
Case Laws Income Tax
Show AI Summary
Strict compliance with exemption conditions: declaration and filing deadline mandatory; revised returns cannot introduce new exemption claims.
The Court held that both conditions for claiming the exemption-furnishing a written declaration to the assessing officer and submitting it before the due date for the original return-are mandatory and must be strictly complied with. It rejected treating the time limit as directory, distinguished deduction-related authorities, and held that a revised return cannot introduce new exemption claims or claim carry-forward benefits not made in the original return.
Case Laws Income Tax
Show AI Summary
Retrospectivity of tax amendment: amendment held prospective; prior rule barring disallowance where no exempt income applies.
The court held that the Finance Act amendment described as "for removal of doubts" cannot be given retrospective effect where it alters prior law; the Finance Bill memorandum fixing commencement determined prospectivity, and existing Division Bench precedent that no disallowance can be made if no exempt income was earned was applied, subject to the ultimate outcome of the pending higher court challenge.
Case Laws Income Tax
Show AI Summary
Charitable purpose clarified: statutory public bodies generally exempt; commercial receipts taxed under quantitative proviso, with annual scrutiny required.
The judgement narrows the scope of charitable purpose under Section 2(15) by treating statutory public utility bodies as generally exempt while excluding income from commercial activities beyond core regulatory or public-interest functions. Trade-promotion and non-statutory bodies may qualify if charges are nominal, but ancillary fee-generating services and high-fee providers produce taxable commercial receipts. Private trusts' advertisement income is commercial. Assessing authorities must perform yearly scrutiny and apply the proviso's quantitative limits to determine exemption eligibility.
Case Laws Income Tax
Show AI Summary
Deduction 80P eligibility turns on whether a cooperative society's banking status classifies it as a cooperative bank; AO to verify.
A cooperative society carrying on deposit-taking and lending, issuing cheques and providing banking services may fall within the banking business definition under the Banking Regulation Act; whether it qualifies as a cooperative bank under that Act-affected by its bye-laws and membership rules-must be determined by fact-specific examination to decide entitlement to the cooperative deduction.
Case Laws Income Tax
Show AI Summary
Condonation of Delay in Filing Form Ten: reasonable professional oversight accepted, delay condoned and rectification allowed.
Condonation of delay in filing Form Ten was granted where the auditor's bona fide oversight-reporting accumulation in the audit report (Form Ten B) and misconstruing separate filing requirements-led to a 361 day delay; the court found the lapse inadvertent amid pandemic conditions, accepted the explanation, quashed the refusal order and permitted rectification steps, treating the delay as condoned.
Case Laws Income Tax
Show AI Summary
Advance tax obligation: absence of taxable income prevents dismissal of appeal for non-payment of advance tax.
The Tribunal held that the advance tax payment condition for appeal maintainability applies only when the assessee had a legal obligation to compute and pay advance tax; in the absence of taxable income no such obligation exists, and an appeal cannot be dismissed solely for non-payment of advance tax. The Tribunal directed that the matter proceed to merits with an opportunity to be heard, stressing that the payment requirement must be applied in light of factual circumstances.

TMI Notes

Back

All TMI Notes

Showing Results for :
Reset Filters
No Records Found

TMI Notes

Back

All TMI Notes

Comparison of section 294 "Procedure for block assessment." between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

10 September, 2025

Contents
Acts
Rules & Regulations
Summary
Note

Note

-

Bookmark

Print

Print

Section 294 Procedure for block assessment

Income-tax Act, 2025

At a Glance

The document is Clause 294 of the Income Tax Bill, 2025 (Old Version): a proposed special procedure for block assessment in search/requisition cases. It matters because it prescribes the notice, return and consequential assessment procedure in high-risk search cases, affecting taxpayers subject to searches and the assessing authority. Who is affected: taxpayers subject to search/ requisition and the Income-tax Department. Effective date or decision date: Not stated in the document.

Background & Scope

Statutory hooks: Clause 294, Income Tax Bill, 2025 (Old Version). Context: procedure to be followed where a search has been initiated or requisition made. Coverage: issuance of notice requiring a return for the block period, treatment of such return, procedural cross-references for assessment and penalties, treatment of seized/requisitioned assets, and prior approval before issuing notice. Definitions or further explanations: Not stated in the document.

Statutory Provision Mode

Text & Scope

  • Clause 294 addresses situations where a search is initiated or requisition made. The Assessing Officer (AO) must issue a notice requiring the person to furnish, within the period specified (not exceeding sixty days), a return "in the form and verified in the manner, as prescribed," setting forth the total income, including undisclosed income, for the block period. The return is to be treated as if furnished u/s 263 and thereafter a notice u/s 270(8) shall be issued. Returns furnished beyond the period are declared not to be returns u/s 259. No notice u/s 280 is required. A person who furnishes such return is not entitled to file a revised return.
  • The AO shall proceed to determine the total income including the undisclosed income for the block period per section 293, and specified provisions (sections 268, 270(8), 270(10), 271, 276, 287 and 288) shall, so far as may be, apply. On such determination, the AO shall pass an order of assessment or reassessment and determine tax payable, with the proviso that section 275 shall not apply; additionally, where the order is made pursuant to section 295, the block period for that assessment shall be the same as that determined in respect of the person in whose case the search was initiated. Assets seized u/s 247 or requisitioned u/s 248 shall be dealt with per section 250. Section 270(1) shall not apply to the return furnished under this section. Prior approval of senior specified officers is required before issuing the notice.

Interpretation

Legislative intent as indicated by the text: to create a distinct, expedited procedure for block assessment following searches/requisitions, by compelling a targeted return within a strict timeframe, limiting revision rights, and specifying which procedural and penal provisions apply. The treatment of such returns "as if" u/s 263 suggests an intent to subject such returns to a particular return regime while ensuring downstream procedure u/s 270(8). The prohibition on revision and on section 270(1) suggests an intent to fix the record and limit post-disclosure tinkering. The requirement for prior supervisory approval indicates a policy of internal checks before initiating the block return procedure.

Exceptions/Provisos

Carve-outs and conditions in the Clause: (i) Section 275 does not apply to orders passed under this Clause; (ii) where assessment/reassessment is u/s 295, block period alignment rule applies (Bill only); (iii) returns filed after the specified period are not deemed returns u/s 259; (iv) section 270(1) does not apply to such returns. Additional procedural limitations: no revised return permitted; no section 280 notice required. Any thresholds, time limits beyond the sixty-day specification: Not stated in the document beyond the sixty-day maximum and the immediate treatment described.

Illustrations

  • Example 1: A search of A's premises leads the AO to issue a clause 294 notice requiring a return within sixty days setting out A's total income including undisclosed income for the block period; A files the return on day 45. The AO treats the return as if u/s 263 and issues notice u/s 270(8) and proceeds under the specified sections to determine tax. (Consistent with text.)
  • Example 2: B files a return in response to a clause 294 notice after the sixty-day period. Under the Clause, that late return "shall not be deemed to be a return u/s 259" (textual provision), and thus would be excluded from the returns regime referenced. (Consistent with text.)
  • Example 3: C is assessed pursuant to section 295 as part of connected proceedings initiated by a search in D's case; the AO sets the block period for C to be the same as for D. (Consistent with clause (c)(ii) in the Bill.)

Interplay

Interaction with other sections mentioned: the Clause expressly imports section 263 procedures for deeming the return, requires issuance of notice u/s 270(8), and prescribes that several other specified sections "shall, so far as may be, apply" (268, 270(8), 270(10), 271, 276, 287, 288). The Clause excludes application of section 275 to resulting orders and excludes section 270(1) from application to the special return. The Clause further references sections 247, 248 and 250 for treatment of seized/requisitioned assets and section 295 for block-period alignment. Any rules, notifications or circulars beyond these sections: Not stated in the document.

Differences between the two provisions and practical impact of each change

  • Content of the return required: The Bill (Clause 294 - Old Version) requires the assessee to furnish "a return ... setting forth his total income, including the undisclosed income, for the block period." The Act (Section 294) requires a return "setting forth his undisclosed income, for the block period."
    • Practical impact: The Bill's wording would have required a composite disclosure of total income plus undisclosed income, potentially generating fuller self-contained disclosures for assessment. The Act narrows the disclosure requirement to undisclosed income only, which may limit the scope of what the assessee must put on record via the special return and could shift emphasis to determination of undisclosed amounts by the AO using other material.
  • Provision for extension (30 days) and conditional grounds: The Act contains an express sub-clause permitting a further extension of 30 days where four specific conditions (A-D) are satisfied (relating to due date not having expired, audit liability u/s 63, accounts not audited, and written request for extension to get accounts audited). The Bill does not contain this extension provision.
    • Practical impact: The Act's explicit extension mechanism gives assessees an administrative safeguard to arrange an audit and furnish audited accounts, reducing risk of procedural non-compliance. The absence of this in the Bill would have imposed a stricter sixty-day deadline with no specified statutory extension, increasing compliance pressure and potential disputes over timeliness.
  • Cross-references to other sections (applicable provisions): The Bill lists the provisions to be applied "so far as may be" as sections 268, 270(8), 270(10), 271, 276, 287 and 288. The Act lists sections 268, 270(8), 270(10), 271, 276, 277 and 278.
    • Practical impact: Different cross-references change which penalty, prosecution or procedural provisions are available. The Bill's inclusion of sections 287 and 288 (and omission of 277/278) would have applied different penal/process provisions than the Act's choice of 277 and 278. This affects potential penalties, prosecution exposure, and consequential procedural steps; taxpayers and authorities will need to re-evaluate the risk/relief profile as per the final list.
  • Returns filed beyond the time allowed - cross-reference discrepancy: The Bill states that any return beyond the period "shall not be deemed to be a return u/s 259" (anomalous reference). The Act states that any return beyond the period "shall not be deemed to be a return u/s 263."
    • Practical impact: The Bill appears to contain an incorrect cross-reference (section 259) which would create ambiguity and possible challenge; the Act corrects this to section 263. The correct cross-reference determines which statutory regime governs validity of late returns in search/block cases, hence critical to procedural consequences.
  • Additional provision in Bill regarding block period alignment where order pursuant to section 295: The Bill contains an additional sub-clause (c)(ii) providing that where assessment/reassessment is made pursuant to section 295, "the block period for such assessment or reassessment shall be the same as that determined in respect of the person in whose case search was initiated..." The Act lacks an equivalent clause.
    • Practical impact: The Bill's clause would have ensured synchronized block periods across related assessments triggered by the same search, clarifying temporal reach of linked proceedings. Its omission in the Act leaves uncertainty whether block periods in consequential proceedings automatically mirror the original searched person's block period; this may affect limitations and taxable periods in follow-on assessments.
  • Minor language and chapter/part references: The Bill refers to "as prescribed" and to proceedings "under this Chapter"; the Act uses "as may be prescribed" and "under this part."
    • Practical impact: Largely stylistic; however, "as may be prescribed" can be read as preserved legislative discretion. The chapter/part wording difference is terminological and unlikely to have substantive legal effect but should be noted for drafting clarity.
  • Common features preserved: Both versions require prior approval of an Additional Commissioner/Additional Director/Joint Commissioner/Joint Director before issuance of the notice; both disallow revision of a return filed under the provision; both state no notice u/s 280 is required for proceeding.
    • Practical impact: These consistent elements preserve administrative checks and constrain assessee's ability to revise disclosures made under the special procedure.

Practical Implications

  • Compliance risks: Filing within the sixty-day window is mandatory; late filings are expressly rendered not to be returns under the cross-referenced provision (section 259 in the Bill), exposing taxpayers to adverse procedural consequences. The inability to file revised returns increases the stakes of initial disclosure entries.
  • Record-keeping: Taxpayers facing search/requisition should be prepared to compile and submit a full return of total income and undisclosed income for the block period within sixty days, along with supporting documents. Maintenance of contemporaneous books and auditable records will be crucial.
  • Audit/assessment strategy: The AO will apply the specified sections to determine undisclosed income, and the exclusion of section 275 indicates penalties under that section will not attach to these orders, though other penalties/prosecutions under the listed sections may apply.
  • Approval requirement: Prior approval by senior officers before issuing the notice imposes an internal control in the Department's process; taxpayers should monitor exercise of that supervisory check.
  • Interconnected assessments: Whether block periods of consequential assessments must align (per clause (c)(ii)) may affect limitation and evidence strategies in linked cases; practitioners should note the Bill's explicit alignment provision.

Key Takeaways

  • Clause 294 prescribes a targeted return procedure in search/requisition cases with a strict sixty-day deadline and no right to revise the return.
  • The return is to be treated "as if" u/s 263 and triggers a notice u/s 270(8); section 270(1) does not apply.
  • Certain penal/procedural sections are specified to apply "so far as may be" (268, 270(8), 270(10), 271, 276, 287, 288), while section 275 is excluded.
  • Clause contains a special alignment rule for block periods where assessment follows section 295.
  • Seized or requisitioned assets are to be dealt with u/s 250; prior approval of senior officers is required before issuing the notice.
  • The Bill's reference to section 259 for late returns appears anomalous and would create ambiguity in application.
  • Practical compliance: rapid assembly of records, attention to timelines, and careful drafting of the initial return are essential.

Full Text:

Section 294 Procedure for block assessment

Topics

Acts Income Tax