Hello Auditor

What is the time limit for completing corporate tax assessments?

Time Limit for Regular Assessment (Section 143(3))

  • The assessment must be completed within 9 months from the end of the relevant assessment year.
  • For assessment year 2023–24, the time limit is December 31, 2024.
  • This applies to scrutiny assessments initiated under section 143(2).
  • The period may be extended in special cases or if extended by law.
  • Regular assessments examine the correctness and completeness of returns.

Time Limit for Best Judgment Assessment (Section 144)

  • If the assessee fails to comply with notices or requirements, a best judgment assessment is made.
  • The same time limit of 9 months from the end of the assessment year applies.
  • The assessing officer proceeds based on available information and records.
  • Delay in submission of details or non-cooperation may lead to this action.
  • No further extension is allowed unless provided by a specific notification.

Time Limit for Reassessment (Section 147 and 148)

  • Reassessment is initiated when income has escaped assessment.
  • Notice under section 148 can be issued within 3 years from the end of the relevant assessment year.
  • In cases involving income escaping ₹50 lakh or more, the limit extends to 10 years.
  • Reassessment must be completed within 12 months from the end of the financial year in which notice was served.
  • All timelines are subject to conditions specified in the amended provisions.

Time Limit for Transfer Pricing Cases

  • If the case involves an international transaction requiring a reference to the Transfer Pricing Officer, additional time is granted.
  • The time limit for assessment is extended by 12 months.
  • For such cases, scrutiny assessment may extend to a total of 21 months.
  • Transfer pricing adjustments may significantly impact the tax liability.
  • Companies must keep detailed documentation to meet this extended deadline.

Exclusions and Exceptions

  • Time periods are excluded for stay orders, reassessment proceedings, and court interventions.
  • Delay due to audit objections, tribunal orders, or cross-border information requests may extend timelines.
  • In case of search or seizure (under section 132), assessment must be completed within 12 months from the end of the relevant financial year.
  • Amendments by Finance Acts may revise or reduce prescribed timelines.

The final order must be issued within the statutory time limit or becomes invalid.

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