Just a moment...

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 characters0/2000
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 ✕
🔎 TMI Notes - Adv. Search
TEXT SEARCH:

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.
RelevanceDefaultDate
    Role of the Transfer Pricing Officer in Ensuring Arm’s Length Compliance : Clause 166 of the Incom...
    Reframing Arm's Length Pricing in India's Evolving Transfer Pricing Regime : Clause 165 of the Incom...
    Meaning of Specified Domestic Transactions under Clause 164 of Income Tax Bill, 2025 Vs. Section 92B...
    Meaning of International Transaction : Clause 163 of the Income Tax Bill, 2025 Vs. Section 92B of th...
    Case LawsIncome Tax
    Remuneration and interest received by an individual partner from a partnership firm can be subjected...
    Meaning of Associates Enterprise under Clause 162 of the Income Tax Bill, 2025 Vs. Section 92A of th...
    Computation of income arising from international transactions and specified domestic transactions : ...
    Future of Unilateral Agreement relief in India : Clause 160 of the Income Tax Bill, 2025 Vs. Section...
    Streamlining Double Taxation Relief and International Tax Agreements : Clause 159 of Income Tax Bill...
    Comprehensive Reform in International Taxation and Treaty Implementation : Clause 159 of Income Tax ...
    Addressing Cross-Border Taxation of Foreign Retirement Benefits : Clause 158 of Income Tax Bill, 202...
    Continuity and Reform in Tax Relief for Irregular Income : Clause 157 of the Income Tax Bill, 2025 V...
    Constitutional Limits on GST: Principle of mutuality insulates transactions between clubs/associatio...
    Relief to resident individual taxpayers with lower and middle incomes by reducing their effective ta...
    The Structure and Implications of Income Tax Rebates : Clause 155 of the Income Tax Bill, 2025 Vs. S...
    Analyzing the Tax Treatment of Collective Entities under Clause 310 of Income Tax Bill, 2025 Vs. Sec...
    Tax Deductions for Persons with Disabilities : Clause 154 of the Income Tax Bill, 2025 vs. Section 8...
    Statutory deduction for interest income derived from deposits : Clause 153 of the Income Tax Bill, 2...
    Patent Royalty Deduction Scheme to Boost Innovation and R&D in India : Clause 152 of the Income Tax ...
    Incentivize and support authors by providing a tax deduction on royalty and copyright income : Claus...
❯❯
MaximizeMaximizeMaximize
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 SummariesHide All Summaries
    Act RulesBills
    Show AI Summary
    Arm's length pricing: multi year ALP option expands certainty and permits roll forward of transfer pricing determinations.
    Clause 166 authorises the Assessing Officer to refer international and specified domestic related party transactions to a Transfer Pricing Officer for determination of the arm's length price, subject to prior approval; mandates notice, hearing, prescribed transfer pricing methods, and communication of the TPO order to AO and assessee; empowers the TPO to examine unreported transactions and to validate a taxpayer's option to apply a determined ALP to similar subsequent years, with rectification powers and corresponding AO amendment obligations, and permits issuance of Board guidelines to implement the multi year regime.
    Act RulesBills
    Show AI Summary
    Arm's length price determination: new clause refines methods and AO powers, emphasizing documentation and prescribed procedures.
    Determination of Arm's Length Price requires selecting the most appropriate method from prescribed alternatives based on the transaction's nature, associated enterprise class, and functional analysis; where a single comparable price is found it is the arm's length price subject to a prescribed tolerance, while multiple prices must be reconciled in a prescribed manner. The tax authority may determine ALP during assessment if methods were not followed or documentation is inadequate, but must issue a show cause notice before adjustment; adjustments permit recomputation of total income and restrict deductions on enhanced income, with safeguards to prevent double adjustment.
    Act RulesBills
    Show AI Summary
    Specified domestic transaction: extending transfer pricing to high-value related-party domestic dealings, subject to arm's length compliance.
    Clause 164 defines specified domestic transaction by enumerating categories of non-international related-party dealings brought under transfer pricing when aggregate annual value exceeds a high-value threshold, includes a residual prescription power to notify additional transactions, and requires contemporaneous documentation and benchmarking to ensure compliance with the arm's length principle.
    Act RulesBills
    Show AI Summary
    International transaction scope expanded broadens transfer pricing coverage to intangibles and indirect dealings, including restructuring and financing arrangements.
    Clause 163 defines international transaction expansively to include tangible and intangible property (expressly including transfer), capital financing, services, business restructuring, cost sharing and any transaction affecting profits, income, losses or assets; it reproduces an illustrative list of intangibles and contains a deeming rule treating dealings with third parties as international transactions where terms are determined with or pursuant to an associated enterprise, thereby widening transfer pricing coverage and anti avoidance reach.
    Case LawsIncome Tax
    Show AI Summary
    Presumptive taxation: partner remuneration and interest cannot be treated as individual business turnover for presumptive tax purposes.
    Section 44AD applies only where the assessee carries on an eligible business and has actual turnover or gross receipts attributable to that assessee. Remuneration and interest paid by a partnership firm to a partner arise from the firm's accounts and partnership agreement; although Section 28(v) taxes such receipts in the hands of the partner, that deeming does not convert them into the partner's turnover or gross receipts for Section 44AD. Section 40(b) governs firm deductibility but does not create an independent business activity in the partner; hence such receipts cannot be subjected to Section 44AD presumptive taxation.
    Act RulesBills
    Show AI Summary
    Associated enterprise definition expands transfer pricing scope to include specified domestic transactions and indirect control.
    Clause 162 defines associated enterprise through a general limb covering direct or indirect participation in management, control or capital and a list of deeming provisions-equity thresholds, significant loans and guarantees, board control, dependence on intangibles, supply and sales dependence, and familial/HUF control-while expressly extending the concept to specified domestic transactions and retaining prescribed catch-all and subjective influence tests that may require further guidance.
    Act RulesBills
    Show AI Summary
    Arm's length price requirement drives transfer pricing adjustments to prevent profit shifting and protect the tax base.
    Clause 161 mandates computation of income and the allowance of expenses or interest for international and specified domestic transactions among associated enterprises with reference to the arm's length price, requires arm's length allocation for shared costs or services, and prohibits transfer pricing adjustments that would reduce taxable income or increase losses, thereby strengthening scrutiny of intra group cost allocations and deductions to prevent profit shifting.
    Act RulesBills
    Show AI Summary
    Unilateral double taxation relief limits credit to the lower of domestic or foreign tax rates and requires proof of foreign tax payment.
    Clause 160 provides unilateral relief for Indian residents and non-resident partners taxed on foreign income where no DTAA exists, limited to the lower of the Indian tax rate or the foreign tax rate, requires proof of foreign tax payment, and defines key terms to include excess profits or business profits taxes; it modernizes terminology and omits a prior country-specific carve-out, while raising evidentiary and computational ambiguities.
    Act RulesBills
    Show AI Summary
    Double taxation relief framework modernised: new clause clarifies treaty adoption, anti abuse safeguards, and documentation requirements.
    Clause 159 empowers the Central Government to enter into and adopt agreements with foreign countries and notified specified territories, and permits specified domestic associations to enter into sectoral agreements subject to governmental adoption and notification. Agreements may provide relief from double taxation, avoidance of double taxation constrained by anti abuse safeguards, exchange of information to prevent evasion, and mutual assistance in tax recovery. The Act's provisions apply to the extent more beneficial to the taxpayer, but anti abuse measures in Chapter XI apply notwithstanding such benefit. Non residents must furnish a certificate of residence and prescribed documentation to claim treaty relief.
    Act RulesBills
    Show AI Summary
    Treaty interpretation and anti-abuse primacy clarified: government may adopt association agreements while preserving treaty benefit limits.
    Clause 159 authorises the Central Government to enter into agreements with foreign countries or notified territories and to adopt agreements between notified specified associations for double taxation relief, exchange of information, and mutual assistance in recovery. Taxpayers may claim the more beneficial of domestic law or a notified agreement, subject to documentary requirements for non-residents and the primacy of chapter-level anti-abuse provisions. A four-tier interpretive hierarchy for treaty terms is provided, with retrospective effect from the agreement's commencement.
    Act RulesBills
    Show AI Summary
    Relief from taxation on foreign retirement accounts aligns Indian tax timing with foreign withdrawal taxation to prevent double taxation.
    Clause 158 aligns Indian taxation of income from foreign retirement accounts with the foreign tax event by restricting relief to specified accounts in notified countries opened while the taxpayer was non resident, and by delegating timing and procedural details to rules to prevent double taxation, address timing mismatches, and guard against abuse.
    Act RulesBills
    Show AI Summary
    Relief for irregular salary receipts: claim based allocation to prior years with computation and procedures delegated to rules.
    Clause 157 provides relief where lump sum receipts (arrear or advance salary, salary for over twelve months, profits in lieu of salary, and arrears of family pension) cause an assessment at a higher rate. Relief is claim based on application to the Assessing Officer and requires allocation of amounts to earlier years; the Assessing Officer grants relief as prescribed in rules. An anti abuse exclusion denies relief where a deduction for the same amount has already been claimed, and computation, procedural steps and particulars (e.g., Form 10E practice) are to be specified by rules.
    Case LawsGST
    Show AI Summary
    Mutuality doctrine shields club-member transactions from GST; statutory deeming fiction held unconstitutional, retrospective levy invalid.
    The Kerala High Court held that the doctrine of mutuality insulates transactions between an association and its members from GST because the concepts of "supply" and "service" require distinct persons; statutory deeming provisions treating associations and members as separate persons are ultra vires Article 246A and related constitutional provisions, and retrospective application of those amendments is invalid as unfair and contrary to the rule of law.
    Act RulesBills
    Show AI Summary
    Rebate for resident individuals: expanded two-tier relief and tapered withdrawal to avoid abrupt tax cliffs.
    Clause 156 creates a two-tier rebate: a general rebate for resident individuals below a base threshold and an enhanced rebate for taxpayers opting into the new tax regime with a higher threshold and larger maximum rebate. The enhanced rebate includes a tapering mechanism for incomes above its threshold and an express cap preventing the rebate from exceeding actual tax liability, with computation rules tied to the new-regime tax rates.
    Act RulesBills
    Show AI Summary
    Rebate allowance framework modernisation - rebates applied after tax computation and capped to prevent negative tax liability.
    Allowance of rebates is enabled by Clause 155, which permits rebates to be deducted from income-tax computed on total income after tax computation and before other chapter deductions, and caps aggregate rebates so they cannot exceed the tax computed prior to rebates; the substantive conditions and limits are delegated to Section 156.
    Act RulesBills
    Show AI Summary
    Taxation of member's share: entity-level tax exempts members, unless the entity is untaxed or taxed below top rate.
    Clause 310 establishes that a member's share of income from an AOP/BOI is exempt from tax in the member's hands when the association/body is taxed on that income; if the AOP/BOI is not chargeable to tax the member's share is taxed in the member's hands; and if the AOP/BOI is taxed at the maximum marginal rate the member's share is excluded from his total income, otherwise the member's share is included in his total income.
    Act RulesBills
    Show AI Summary
    Deduction for disability: standardized tax relief retained with mandatory medical certification and prescribed certificate submission.
    Clause 154 allows resident individuals certified by a medical authority as persons with disability or severe disability to claim a fixed deduction, contingent on furnishing the prescribed certificate with the return and on certificate validity and reassessment rules; definitions are cross referenced to a Bill provision for consistency.
    Act RulesBills
    Show AI Summary
    Deduction for interest on deposits expanded to include senior citizens and time deposits, consolidating small-saver relief.
    Clause 153 provides a statutory deduction for interest on deposits to individuals, senior citizens, and HUFs, specifying eligible institutions (banks, cooperative banking societies, and post offices), preserving denial of deductions for interest held by or on behalf of firms, AOPs, or BOIs, and defining time deposits. It consolidates prior disparate provisions by including senior citizens within the same clause with expanded coverage for time deposits, while maintaining the existing deduction treatment for non senior individuals and HUFs.
    Act RulesBills
    Show AI Summary
    Patent royalty deduction for resident inventors: capped, certified relief tied to repatriated foreign receipts and compulsory licence limits.
    Clause 152 provides a statutory deduction for resident individual patentees in respect of royalty from patents registered on or after 1 April 2003, subject to a statutory annual ceiling and procedural certification. Deductions in compulsory licence cases are limited to Controller determined royalty; foreign-sourced receipts qualify only to the extent repatriated in convertible foreign exchange within the prescribed period and supported by prescribed certification. Definitions exclude capital gains and sales proceeds from the scope of "royalty," and certification by prescribed authorities is required with the return.
    Act RulesBills
    Show AI Summary
    Deduction for authors' royalty income limited by a fixed cap and repatriation plus certification requirements.
    Clause 151 grants a deduction to resident individual authors for professional income from copyright assignment or royalties for literary, artistic, or scientific books (excluding textbooks), subject to a fixed monetary cap and a royalty to sales limit for non lump sum receipts. Foreign income qualifies only if repatriated in convertible exchange within a prescribed period and accompanied by prescribed certification, and claimants must submit payer verified certificates with returns; double deduction for the same income is expressly prohibited.

    TMI Notes

    Back

    All TMI Notes

    Showing Results for :
    Reset Filters
      No Records Found

      TMI Notes

      Back

      All TMI Notes

      whatsappJoin Channel
      Showing Results for : Reset Filters

      Comparison of section 296 "Time-limit for completion of 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 296 Time-limit for completion of block assessment

      Income-tax Act, 2025

      At a Glance

      The document under detailed consideration is Clause 296 of the Income Tax Bill, 2025 - (Old Version) which prescribes the time-limits and exclusion rules for completion of block assessments under the special procedure for search cases (section 294). It matters to taxpayers subjected to search and seizure proceedings, their representatives, and the Income-tax Department. The Bill text sets out computation rules, specified exclusions, and minimum remaining-period safeguards. Effective date or enactment status: Not stated in the document.

      Background & Scope

      Statutory hooks: Clause 296 (Bill) interacts primarily with section 294 (orders following search), section 295 (other persons), section 166(1) (references), section 159 (agreements for exchange of information), sections 244(2), 268(5), 269(1), 270(11)(i), 270(13), 274(1), and chapters dealing with Advance Rulings (sections 381 and 384 cited in the Bill). The Clause sets time-limits for passing assessment orders under the special search/block-assessment procedure and prescribes periods that are to be excluded in computing limitation. Definitions or explanatory notes: Not stated in the document beyond cross-references to the cited sections.

      Statutory Provision Mode

      Text & Scope

      Clause 296 prescribes that an order u/s 294 must be passed within twelve months from the end of the month in which the last of the authorisations for search was executed or requisition was made (sub-s. (1)). It applies "irrespective of the provisions of section 296" (likely an editorial inconsistency in the Bill text: see Interplay). The clause covers both the primary assessee and "other persons" (section 295) with separate computation for the latter (sub-s. (5)). It also provides for a 12-month extension where a reference u/s 166(1) is made during the course of proceedings (sub-ss. (2) and (6)).

      Interpretation

      The Bill text indicates an intent to fix a relatively short, definite time-frame (12 months) from a clear calendar point (end of the month in which the last search authorisation was executed or requisition made), subject to specified exclusions and extensions. The inclusion of enumerated excluded periods suggests the legislative principle that certain delays (court stays, information exchange, valuation/audit directions, references to authorities) should not count against the statutory limit. The use of calendar-month endpoints and an explicit minimum remaining period mechanism (sub-s. (8)) reflects an aim to provide practical breathing space for completion after exclusion periods. Legislative intent beyond these textual signals: Not stated in the document.

      Exceptions/Provisos

      Key carve-outs and conditions in the Clause:

      • Exclusion of a period (not exceeding 180 days) from date of search/requisition to date on which seized/requisitioned items are handed over to the Assessing Officer having jurisdiction (sub-s. (3)).
      • Enumerated exclusions in sub-s. (7): court stay periods (until certified copy of vacating order received), exchange-of-information reference periods (up to last receipt or one year, whichever less), time for reopening or re-hearing u/s 244(2), time taken where assessee is directed to get accounts audited/inventory valued u/s 268(5), period for reference to Valuation Officer u/s 269(1), periods linked to contraventions under Schedule III as per section 270(11)(i), references to Principal Commissioner/Commissioner u/s 270(13), periods relating to impermissible avoidance arrangement references u/s 274(1), and periods for Board for Advance Rulings applications and pronouncements u/ss 381/384 (sub-ss. (7)(a) to (j)).
      • Minimum remaining-period protection: where, after exclusion under (3) or (7), the remaining period is less than sixty days, it is extended to sixty days (sub-s. (8)).
      • Month-end extension: if after exclusions or extensions the period would expire before month end, it is extended to end of that month (sub-s. (4) and (9)).

      Illustrations

      • Example 1: Search executed on 10 January. Last authorisation executed that month. The normal limitation runs to 31 January of the next year (twelve months from end of the month of execution). If 120 days elapse between search and physical handover and are excluded under sub-s. (3), the remaining period is computed after excluding that 120-day span and then adjusted under sub-s. (4) or (8) as applicable.
      • Example 2: During assessment a reference u/s 166(1) is made. The time available for completion is extended by twelve months under sub-s. (2).
      • Example 3: A court grants a stay on assessment for 90 days; the stay is vacated and the jurisdictional Principal Commissioner receives certified copy 100 days later. The stay period (start to certified copy receipt) is excluded under sub-s. (7)(a) from computation.

      Interplay

      The Clause expressly interacts with multiple provisions: section 294 (orders after search), section 295 (other persons), section 166 (references), section 159 (exchange of information), section 244(2) (re-hearing/reopening), sections 268-269 (audit/valuation), section 270 (penalty/procedure references), section 274 (avoidance arrangements), and the Advance Rulings provisions (sections 381/384). The Bill text does not refer to any subordinate Rules, notifications or circulars. Potential textual inconsistency: sub-s. (1) refers to "Irrespective of the provisions of section 296", which appears circular or mis-referenced (likely intended to refer to another section-Not stated in the document).

      Practical Implications

      • Compliance and risk areas: Tax officers must track multiple exclusion events and maintain documentary proof (dates of handover of seized items, certified copies of court orders, dates of receipt of exchanged information, audit/valuation reports, Valuation Officer reports, advance ruling communications). Failure to accurately compute exclusions could result in time-bar disputes. The Bill requires attention to the precise calendar endpoint ("end of the month") for initial limitation calculation.
      • Record-keeping/evidence points: The text implicitly requires records showing the date of search/requisition, date of handover of seized/requisitioned items, dates of service/receipt of certified copies of court orders and authority communications, dates of references and replies under information-exchange, dates of audit/inventory valuation directions and reports, reports from Valuation Officer, and communications from the Board for Advance Rulings. Specific required forms or formats: Not stated in the document.

      Key Takeaways

      • Clause 296 fixes a twelve-month period (from end of the month of last search authorisation/requisition) for completion of block assessment orders u/s 294.
      • Specified exclusions (including up to 180 days for seizure custody and a series of procedural delays) are carved out from limitation computation.
      • A 12-month extension applies where a reference u/s 166(1) is made during proceedings (for primary assessee and separately for "other persons").
      • Where exclusions leave less than sixty days to proceed, the remaining period is extended to sixty days, creating a minimum workable timeframe post-exclusions.
      • Month-end rounding rules extend expiry to the end of the month if the period would otherwise expire mid-month.
      • The Clause requires careful tracking of multiple external events and receipt dates; however, procedural forms, judicial or administrative guidance on computation: Not stated in the document.
      • Textual inconsistency in sub-section (1) referring to "provisions of section 296": Not explained in the document.

      Differences Between (Document 2) Clause 296 of the Income Tax Bill, 2025 - Old Version and (Document 1) Section 296 of the Income-tax Act, 2025

      • Trigger point for the twelve-month period: Bill uses "twelve months from the end of the month in which the last of the authorisations for search was executed, or requisition was made" (Bill sub-s. (1)). The Act uses "twelve months from the end of the quarter in which the last of the authorisations for search was executed, or requisition was made" (Act sub-s. (1)(a)).
        • Practical impact: The Act lengthens the period by aligning to quarter ends rather than month ends, effectively giving up to approximately three additional months in some cases for completion, reducing pressure on the department (more time) and increasing uncertainty for taxpayers about the precise deadline (wider window).
      • Provision for extension where return-filing time is extended: The Act contains sub-s. (1)(b) stating that if the time for furnishing return u/s 294(1)(a)(v) is extended by 30 days, "twelve months" is to be read as "thirteen months". This is absent in the Bill.
        • Practical impact: Act expressly accommodates administrative extensions for return filing; the Bill silent on that contingency.
      • Seizure/exclusion wording: Bill excludes "the period (not exceeding one hundred eighty days) commencing from the date on which a search is initiated or a requisition is made and ending on the date on which seized or requisitioned items are handed over to the Assessing Officer having jurisdiction over the assessee" (Bill sub-s. (3)). The Act is more specific in sub-s. (3): it refers to assets [as provided in section 261(b)] and material seized or requisitioned [as provided in section 261(i)] are handed over to the Assessing Officer having jurisdiction.
        • Practical impact: Act clarifies the nature of items (cross-referring to section 261 definitions) which may reduce disputes about what constitutes seized items; Bill is more general.
      • Detailed sub-sectioning and drafting refinements: The Act expands certain sub-section numbering and presents the "quarter" rule, an additional clause for extension linked to return-filing, and adds or rearranges textual clarifications for persons u/s 295 (Act sub-s. (5) refers to "twelve months from the end of the quarter in which the notice u/s 294 in pursuance of section 295, was issued ..."). The Bill refers to "end of the month".
        • Practical impact: For "other persons" (section 295), the Act again gives a quarter-end anchor, providing more time compared to the Bill's month-end anchor.
      • Order of exclusions and minor drafting differences: The Act reorders or clarifies some exclusion clauses, and in some instances expands wording to refer to delivery/receipt to Principal Commissioner/Commissioner or Assessing Officer.
      • Practical impact: The Act's drafting appears designed to reduce ambiguity on receipt events and which authority's receipt triggers cessation of exclusion; the Bill is less explicit in certain respects.
      • Other differences: The Act includes an explicit sub-s. (8) and (9) analogous to the Bill but keyed to quarter-end based primary limitations.
        • Practical impact: Overall the Act tends to provide marginally more time and greater specificity on what is excluded and how computation is to be anchored.

      Action Points

      • Parties should maintain contemporaneous records establishing dates of search/requisition, dates of handover of seized items, certified copies of court orders, communications for exchange of information, references and reports from Valuation Officer, audit/inventory valuation reports, and Board for Advance Rulings communications.
      • Practitioners should note whether the operative limitation is computed from month-end (Bill) or quarter-end (Act) when advising clients and tracking deadlines; post-enactment, use the Act wording (quarter-end) where applicable.
      • In disputes, ensure pleadings and computation tables explicitly apply the correct anchor (month vs quarter) and list excluded periods with documentary proof of receipt dates.

      Full Text:

      Section 296 Time-limit for completion of block assessment

      Topics

      ActsIncome Tax