Return Filing & Assessment Procedure |

Notes on

Return Filing & Assessment Procedure

Section 139(1): Filing of Return of Income (ROI)

For following return filing is mandatory:

o Company
o Partnership Firm (Including LLP)
o Other Assessee if his GTI > Basic Exemption Limit
 GTI = Income before claiming exemption u/s 54, 54B, 54D, 54EC, 54F, 54G,
54GA
o Resident Individual who is beneficial owner of any asset outside India
o Resident Individual who has signing authority in any account outside India
o Resident Individual who is beneficiary of any asset outside India
 Beneficiary = Deriving Benefit from asset of other (paid by) person
 Beneficial Owner = Paying for asset for future benefit
o Assessee who deposited aggregate of more than 1 CR in current account(s) in PY
o Assessee who deposited aggregate of more than 50 LAKH in saving account(s) in PY
o Aggregate Foreign Travel Expense > 2 Lakhs in PY for himself or other person
o Aggregate Electricity Consumption Expense > 1 lakh in PY
o Turnover > 60 lakhs in PY in case of business
o Gross Receipts > 10 lakhs in PY in case of business
o Aggregate TDS and TCS in PY > ₹25,000 (₹50,000 for Senior Citizen)

Due Dates of Return

ASSESSEE DUE DATE

- Person required to file Transfer Pricing Audit Report u/s 92E 30th Nov of AY
- Company
- Person whose books are required to be audited under any law
31st Oct of AY
- Person who is partner in a firm, where firm’s books are required to be
audited under any law
- Others 31st July of AY
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Section 139(IC): CG may exempt class of person to file ROI

NR / Foreign Company which have only 1 investment set up in IFSC subject to following
o TDS deducted u/s 194LBB
o Notice is not issued by AO u/s 142(1) or 148
NR / Foreign Company having income from specified fund u/s 10(4D) & provisions of PAN
are not applicable
NR,
o being an eligible foreign investor
o having income from transfer of capital asset referred u/s 47(viiab)
o capital asset shall be listed on recognized stock exchange located in IFSC where
consideration is paid or payable in Foreign Currency
o & provisions of PAN are not applicable

Section 139(3): Loss Return

As per section 80, assessee is required to file return upto due date u/s 139(1) for carry
forward of following losses:
o Business Loss u/s 72(1)
o Speculation Business Loss u/s 73(2)
o Specified business loss u/s 73A(2)
o Loss under head “Capital Gains” u/s 74(1)
o Loss from activity of owning and maintaining race horses u/s 74A(3)
Loss can be set-off even if return filed after due date
HP losses and unabsorbed depreciation can be carried forward even if return late filed

Section 139(4): Belated Return

Belated return can be filed in case due date is missed (whichever earlier of following)
o 31st December of AY
o Completion of Assessment
Specified losses cannot be carried forward u/s 80
No deduction of certain income u/c 6A
1% interest p.m or part on tax payable u/s 234A
Late filing fees u/s 234F
o 5,000 for taxable income > 5 lakhs
o 1,000 for taxable income < 5 lakhs

Section 139(5): Revised Return

In case of error, omission, wrong statement of returns filed u/s 139(1), 139(3), 139(4) return
can be revised on WHICEVER IS EARLIER;
o 31st December of AY
o Completion of Assessment
Return can be revised even if assessee receives intimation or refund u/s 143(1)
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Section 139(9): Defective Return

Return shall be considered defective if;

o Return not filed in prescribed form
o Proofs of tax not attached with return
o Report u/s 44AB (tax audit) not submitted
AO shall intimate defective return to assessee and give 15 days time to rectify the same
If not rectified in time, consider it an INVALID Return

Section 139(4A): Return of Trust

If trust crosses basic exemption limit, then trust is required to file return
Late return penalty of 500 per day applicable

Section 139(4B): Return of Political Party

If Total income before exemption u/s 13A > basic exemption

Political party is required to file return

Section 139(4C): Return of Hospitals, Institutions, etc.

If total income before exemption u/s 10 > basic exemption

Mandatory to file return
Late return penalty of 500 per day applicable

Section 139(4D): Return of College, University, Educational Institution

If approved u/s 35
Return filing is mandatory

Section 140: Verification of Return

Individual Himself
Individual not present in India (or mentally sick) Competent Representative
HUF Karta
Karta not present in India (or mentally sick) Adult Member of Family
Partnership Firm Managing Partner
If there is no Managing Partner Adult Partner of firm
LLP Designated Partner
If there is no Designated Partner Any other adult partner
Company MD
No MD Any other director
Co. under liquidation Liquidator
Co. under Insolvency Insolvency Professional
Political Party CEO
Local Authority Principal Officer
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Section 139B: Tax Return Preparer (TRP)

TRP = Individual authorized by CBDT other than;

o CA
o Legal Practitioner
o Officer in sch. Bank where assessee maintains account
o Employee of company
o Employee of person who is required to get his books audited u/s 44AB (tax audit)
Only individual and HUF are allowed to file return through TRP
Individual holding bachelor’s degree or inter pass of exam of ICAI, ICSI or ICMAI

Section 140A: Self-Assessment Tax

Assessee is required to pay taxes, fees or interest before Filing ITR

After considering TDS, TCS, MAT credit, AMT credit, reliefs
Payment shall be adjusted first towards fees, then interest and balance towards tax

Section 139(8A): Updated Return (w.e.f. 01/04/2022)

Updated return can be submitted within 24 months from end of relevant AY

Any Person can file updated return
If a person has filed return of loss for a PY, he can return of income u/s 139(8A) for that PY
In case, c/f loss, c/f depreciation, c/f MAT or AMT credit is reduced in subsequent years due
to updated return, updated returns shall be furnished for all subsequent years
In simple words, Tax Liability cannot be reduced by updated return, it can only be increased
Updated return cannot be filed in following cases:
o Updated return already furnished
o If updated return is return of loss
o Updated return decreases tax liability
o Search has been initiated u/s 132
o Documents requisitioned u/s 132A
o Survey has been conducted u/ 133 (other than TDS/TCS)
o Assessment, Reassessment, Re-computation, revision pending
o Update in return is due to DTAA u/s 90 and 90A
o Proceedings u/c 22 (Offences and Prosecutions) initiated
o Person belongs of CLASS OF PERSON, notified by CBDT
Additional income tax u/s 140B shall be paid before filing updated return

TAX ON UPDATED RETURN

Updated return is filed within 12 months of completion of AY 25% tax on assessed tax
Updated return is filed after 12 months of completion of AY 50% tax on assessed tax

Here, assessed tax = Total Tax + Interest

(Note: Assessed tax shall not include late filing fees u/s 234F)
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Section 142(1): Enquiry before Assessment

If assessee has not filed Income tax return within time limit u/s 139(1), AO or officer not
below rank of ITO (Income Tax Officer) may issue notice requiring him to file return
For making assessment AO can issue notice:
o To produce books and documents (max. 3 years prior to relevant PY)
o To Furnish information about assets and liabilities (prior approval of JC – Joint
Commissioner Required)

Section 142(2A): Special Audit (Audit by department)

AO can direct special audit for assessee’s books of accounts

Such direction can be issued with prior approval of CIT/CCIT/PCIT/PCCIT
Audit conducted by a CA nominated by CIT/CCIT/PCIT/PCCIT
Remuneration of such audit shall be paid by CG to CA
Such special audit Direction can also be given even if books are audited u/s 44AB
An opportunity of being heard shall be given before directing
Audit report shall be submitted within time decided by AO (not exceeding 180 days)
May attract a penalty of ₹10,000 in case of failure to furnish or furnish within time limit

Section 142A: Reference to Valuation Officer (VO)

AO can make a reference to VO for purpose of assessment to estimate value (FMV) of any:
o Asset
o Property
o Investments
VO shall estimate value of asset after considering evidences produced by assessee
VO shall send a copy of valuation report to AO and Assessee within 6 months from end of
month in which reference was made by AO

Section 142B: Faceless Inquiry or Valuation

Following shall be done in Faceless manner according to section 144B:

o Enquiry before Assessment u/s 141(1)
o Special Audit (Audit by department) u/s 142(2A)
o Reference to valuation officer u/s 142A

Section 143(1): Processing of Return (Intimation)

Where return of income is filed u/s 139, same shall be processed by CPC = Centralised
Processing Centre, after making following adjustments;
o Arithmetical error in return
o Incorrect claim is apparent in return
o Disallowances of losses, expenses, 10AA deductions , 6A deductions if any (or due to
late filing)
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Before making above adjustments, intimation shall be sent to assessee about such
adjustments requiring assessee to respond to such adjustments
o If no response is received within 30 days of intimation, processing of return shall be
carried out incorporating the adjustments
After processing, 2nd intimation shall be sent to assessee for any of the following:
o Refund
o Demand
o Adjustments
o No changes
nd
2 Intimation shall be sent within 9 months from END of FY in which return was filed

Section 143(2): Notice of Scrutiny

For making assessment u/s 143(3), AO or officer not below rank of ITO is required to serve
notice u/s 143(2)
Such notice shall be served within 3 months from end of FY in which return was filed
Notice u/s 143(2) can only be issued after intimation u/s 143(1)

Section 143(3): Order of Scrutiny Assessment

Based on material and evidences furnished by assessee in response to notice u/s 143(2),
AO may pass an order along with determination of tax payable or refundable u/s 143(3)
AO cannot disallow following exemptions; (can inform Govt.)
o Exemption of income of institution engaged in social science, statistical or scientific
research u/s 10(21)
o Exemption of Income of news agency set up in India approved by CG u/s 10(22B)
o Exemption of Income of institution established in India for having object notified by
CG u/s 10(23A)
o Exemption on income of institution not for profit for sale of village products or khadi
products u/s 10(23B)
o Exemption on income received by any person from funds like PM Cares Fund, Clean
Ganga Fund, etc. or charitable trust provision u/s 10(23C)
Should be completed within 9 months from completion of relevant AY

Section 144: Best Judgement Assessment (BJA)

AO shall make an assessment to the best of his judgement and knowledge, in case of
following 4 defaults:
o Failure to furnish return u/s 139(1), 139(4), 139(5), 139(8A)
o Failure to comply with 142(1) (RIA – Return Inquiry Assessment)
o Failure to comply with directions issued u/s 142(2A) (Special Audit)
o Failure to comply with notice u/s 143(2) (Scrutiny Notice)
BJA can only take place after issuing show cause notice u/s 143(2) and after giving an
opportunity of being heard
No refund can be issued u/s 144
BJA Should be completed within 9 months from completion of relevant AY
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Section 144A: Power of Joint Commissioner (JC) to issue directions

JC may call to examine the records of any pending proceedings or pending assessments
Binding directions can be given to AO
Directions prejudicial to assessee can be issued only after giving reasonable opportunity of
being heard
No appeal can be filed against direction
Appeal can be filed against assessment order

Section 144B: Faceless Assessment (Procedure of Faceless Assessment, Reassessment u/s 143(3) or
144 or 147)

National Faceless Assessment Centre (NFAC) shall assign the case selected to assessment
unit (AU) through an automated allocation system (AAS)
NFAC shall intimate the assessee that assessment shall be made as per section 144B
Notice u/s 143(2) or 142(1) shall be served to assessee by NFAC within time limit and
forward the same to AU
AU may make request to NFAC for:
o Documents or evidences from assessee
o Conducting verification from Verification unit (VU) (assigned by AAS)
o Technical assistance from Technical unit (TU) (assigned by AAS)
VU and TU will send report to NFAC for help to be provided to AU
NFAC will send report to AU
AU after considering everything, shall propose determination of income or loss
NFAC shall assign Review Units (RU) through AAS for conducting review of such proposal
Assessee shall file his acceptance to NFAC
Assessee shall file objections to DRP (Dispute Resolution Panel) and NFAC
After completion of assessment, NFAC shall transfer all the electronic records of case to AO
having jurisdiction over said case
All communication u/s 144B shall be done in electronic mode

Section 144C: Reference to DRP (Dispute Resolution Panel)

AO shall follow procedure of forwarding draft order while making assessment in following:
o Foreign Company or Non Resident in whose case AO wants to make variation
prejudicial to assessee
o Other assessee in whose case variation arises on account of order of TPO (transfer
pricing officer) u/s 92CA
AO shall forward copy of draft order to the assessee
Within 30 days of receipt of draft order assessee shall
o File his acceptance to AO
o File objections to AO and DRP
In case assessee accepts draft order, AO shall pass final order within 1 month from end of
month in which draft order was accepted
In case assessee objects draft order, DRP shall pass directions to AO within 9 month from end
of month in which draft order was forwarded to assessee
After receiving directions (such directions are BINDING) from DRP, AO shall pass final order
within 1 month from end of month in which directions were received
CG may notify scheme of faceless issuance of directions by DRP till 31.03.2024
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Section 145(1): Method of Accounting

PGBP – Cash or Mercantile

IFOS – Cash or Mercantile
Salary – No Method (Taxable as per rules specified to it)
CG – No Method (Taxable as per rules specified to it)
HP – No Method (Taxable as per rules specified to it)

Section 145(2): Income Computation and Disclosure Standards (ICDS)

10 ICDS notified
Applicable from AY 17-18
Applicable to All Assessee except;
o Individual not required to get books audited u/s 44AB (Tax Audit)
o HUF not required to get books audited u/s 44AB (Tax Audit)

Section 145(3): Discretionery BJA

In following cases AO may take and complete the assessment;

o AO not satisfied about completeness or correctness of books and documents
o Correct method of accounting was not regularly followed by assessee
o ICDS not followed by assessee for computation of income

Section 145B: Taxability of Certain Income

Interest received on late compensation shall be taxable in year of receipt

Govt. grant shall be taxable in year in which it is accrued or received (whichever is earlier)
Reasonable certainty of realisation of claim for escalation of price in contract in PY when
such certainty is achieved
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Section 116: Income Tax Authorities

CBDT

Assessment Investigation
Wing Wing

Principal Chief Principal Director

Commissioner of General of IT
IT (PCCIT) (PDGIT)

Chief
Director General
Commissioner of
of IT (DGIT)
IT (CCIT)

Principal
Principal Director
Commissioner of
of IT (PDIT)
IT (PCIT)

Commissioner of Director of
IT (CIT) Income Tax (DIT)

Assessing officers: Assessing Officers:

- Additionl CIT - Additional DIT
- Joint Commissioner (JC) Joint Director (JD)
- AC/ DC Assistant / - AD/DD Assistant / Deputy
Deputy Commissioner Director
- ITO (Income Tax
Officer)

Tax Recovery Officer

and Inpector of IT

Note: CIT(A) is also IT Authority as per section 116

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Section 119: Power of CBDT to issue orders, instructions, and circulars

CBDT can issue orders, instructions and circulars to its subordinates for administration of act
However, CBDT cannot issue orders:
o Which require IT Authority to make particular assessment in a particular manner
o To Interfere with the discretion of CIT(A) in the exercise of his appellate functions
CBDT can relax certain provisions of act for removing difficulties, (example – extension of due
date)
CBDT can pass general or specific order authorising IT authorities [other than CIT(A)] to
admit certain claim, exemption, deduction, refund, C/F, etc. made even after expiry of
prescribed period

Section 119A: Taxpayer Charter

Income tax department is committed to:

o Provide fair, courteous and reasonable treatment
o Treat taxpayer as honest
o Provide mechanism for appeal and review
o Provide complete and accurate information
o Provide timely decisions
o Collect correct amount of tax
o Maintain taxpayer’s confidentiality
Income tax department expects taxpayers to:
o Be honest and compliant
o Be informed
o Keep accurate records
o Adhere to the time limits
o Pay due amount in full

Section 120: Jurisdiction of Income Tax Authority

Jurisdiction is allotted on the basis of :

Territorial Area Example – Pin Code

Class of Person Example – Company, Individual, etc.
Class of Income Example – Salary, PGBP, etc.
Class of Cases Example – Professionals like CAs, Doctors, etc.

Section 124: Jurisdiction of Assessing Officer

Once jurisdiction of an area is allotted to AO, he can exercise jurisdiction over any person
within that area
In case of dispute over jurisdiction, AO shall refer to higher authorities
Assessee can also challenge jurisdiction of AO within the following limits:

In case ROI Filed u/s 139(1) (whichever is earlier) In case ROI not Filed (whichever is earlier)
1 month from date of receipt of notice u/s Within the limit allowed in notice u/s
142(1) or 143(2) 142(1) or 148 to furnish ROI
Before completion of assessment Within limit allowed in a show cause
notice u/s 144 to show a cause
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Section 127: Power to transfer Cases

CCIT/CIT can transfer case from AO to another AO after giving reasonable opportunity of
being heard to assessee
No need to give reasonable oppourunity of being heard if case is to be transferred within
same city, Town, or Locality

Section 130: Faceless Jurisdiction by IT Authority

Jurisdiction of IT Authority u/s 120 shall be done in faceless manner

Section 131: Power of IT Authority

IT authority shall have all the powers mentioned in Code of Civil Procedure (CPC), 1908;
o Discovery and Inspection
o Examining persons on oath
o Compelling the production of books and documents
o Issuing Commission (Summons)
o IT Authority can impound books of accounts for max. 15 working days

Section 133: Power to call information

IT authority can call information from any person

Section 133B: Power to collect information

IT authority may enter business premises and collect information from there

Section 135A: Faceless collections of information

Any information shall be collected or called in a faceless manner

Section 133A: Power to Survey

IT Authority may enter business premises with PRIOR APPROVAL of any of the:
o PDGIT
o DGIT
o PCCIT
o CCIT
Upon entering they can do:
o Inspect books of accounts and documents
o Check or verify cash or stock or assets
o Place marks of identification on books of accounts and documents
o Impound books of accounts (for max. 15 days)
o Record statement of any person
If books are kept at other place, other place is also covered under this section
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Entry is restricted to before sunset and after sunrise

o NOTE: Only Entry is Restricted here
If person does not co-operate in survey, IT authority shall issue summons u/s 131
Can also conduct survey at function, ceremony or event but after conclusion of such
function, ceremony or event
TDS/TCS survey same as above (but cannot impound books of accounts)

Section 132: Procedure to Search and Seizure (RAID)

Who can authorize Search Warrants:

o PCCIT / CCIT / PDGIT / DGIT
o PCIT / CIT / PDIT / DIT
o Additional CIT / DIT
o JC/JD
When can search be authorized;
o IT Authority have reasons to believe that assessee may fail to produce books of
accounts or documents to whom notice u/s 142(1) or summons u/s 131 is issued
o IT Authority have reasons to believe that assessee is in possession of undisclosed
money, jewellery, other valuable articles
Powers:
o Power to Enter suspected building, place, vessel, aircraft, vehicle
o Power to break locks if keys are not available (DAYAA DARVAZAAA TODD)
o Power to search any person going in(out) of the suspected place (or vehicle)
o Power to ask for passwords if data is maintained electronically
o Seizing books of accounts, docs, money, etc.
 NOTE: STOCK cannot be seized
o Power to pass order to not remove or deal with seized asset for max. 60 days where
 Seizure is not possible due to volume, dimensions, weight, nature, etc.
 Not practicable to take physical possession
Presumptions:
o If suspected assets found from suspected place, such things belongs to assessee
even if he denies
o Presuming that content of books of accounts are true (no changes allowed)
Section 132(9A): Authorized officer shall hand over seized or possessed assets to AO having
jurisdiction over assessee within 60 days from the date on which search was completed
Section 132(9B): Property may be provisionally attached (sealed) by authorized officer within
60 days from the date on which search was completed
o However this attachment is only valid for 6 months
Section 132(9D): Authorized officer may make reference to valuation officer to know the
FMV of asset within 60 days from the date on which search was completed
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Section 132B: Application of books of accounts and assets seized

Books of accounts and documents

o Books of accounts and docs shall be released within 30 days from the date of
completion of assessment u/s 143(3) or 144 or 147
o For retaining books of accounts and docs beyond this period, permission of CCIT/CIT
is required
Money, Bullion, Jewellery, other valuable assets
o Assessee shall make an application within 30 days from end of month in which such
assets were seized
o If AO is satisfied, with prior approval of CCIT / CIT, assets can be released
o Such assets shall be released within 120 days from the date on which search was
completed u/s 132
o Money can be used or assets can be sold for adjusting tax liability
Interest of 0.5% per month or part thereof shall be paid on following:
o Assets + Money – Tax Liabilities = Net Assets Seized (NAS)
o Such interest shall be payable from date immediately following the period of 120
days from the date on which search was completed u/s 132

Section 147: Income Escaping Assessment or Reassessment (Reopening of Case)

For any income of any assessee escaped assessment for an AY, sections from 148 to 153 are
applicable
Notice shall be given u/s 148 only after following procedure u/s 148A

Section 148: Issue of Notice

AO shall serve notice to assessee along with copy of order passed u/s 148A
Return shall be filed by assessee u/s 148 if notice is issued
Such return cannot be revised
Notice u/s 148 can only be issued if following conditions satisfy
o AO having info.
 In accordance with risk management strategy of CBDT (eg. SFT transaction)
 Audit objection
 Info. Received u/s 90 or 90A (DTAA)
 Info. Not made available to AO as per 135A (Faceless)
o AO obtained approval of higher authority u/s 151
In following cases it shall be deemed that AO haves info.
o Search u/s 132
o Survey u/s 133A

Section 148A: Conducting Inquiry, providing opportunity before issuing notice

Conduct any Enquiry with approval of higher authority

Provide opportunity of being heard by serving SCN (Show Cause Notice)
Accept reply within 7 to 30 days, can extend this limit if application made by assessee
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Order u/s 148A shall be passed within 1 month from end of month in which SCN was replied
Appeal to CIT(A)/ITAT not possible against order u/s 148A
Assessee can file WRIT (Petition) to high court if natural justice not complied by AO
This section not applicable if Search u/s 132 already initiated

Section 148B: AO shall not be below rank of JC for assessment or reassessment or re-computation
where search u/s 132 is already initiated or survey u/s 132A is being conducted

Section 149: Time limit for issue of notice u/s 148

Notice can be issued upto 3 years from end of Relevant AY

Notice can be issued upto 10 years from end of Relevant AY (if income escaped amount is
likely to exceed ₹50 lakhs)
Time limit to issue notice shall be extended by time taken by assessee to file RESPONSE
against show cause notice u/s 148A

Section 150: Unlimited time limit to issue notice u/s 148

If re-assessment is to be carried out on directions passed by CIT(A), ITAT, HC, SC, or any court
No limit to issue notice u/s 148

Section 151: Sanction for issue of notice u/s 148 and 148A

Within 3 years from end of Relevant AY – CIT/PCIT/DIT/PDIT

After 3 years from end of Relevant AY – PCCIT/PDGIT

Section 152(1): Tax Rate for Escaped Income

Respective AY’s tax rate shall apply

Section 152(2): Dropping Assessment Proceedings u/s 147

If AO satisfies himself that there wont be any tax effect due to this assessment, assessment
may be dropped

Section 153(2): Time limit to complete the assessment

12 months from end of FY in which notice u/s 148 was served

Such income escaping assessment shall be done in a faceless manner prescribed u/s 144B
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Section 154: Rectification of Mistake

If there is any mistake in:

o Order passed by authority
o Intimation 143(1)
o TDS/TCS intimation u/s 200A / 206CB
Rectification can be done:
o Within 4 years from end of FY in which order was passed which contained mistake
o In case application is made by assessee, within 6 months from end of month in
which application is made by assessee (assessee can make application even after 4
years)

Section 156: Demand Notice

Assessee should pay the demanded amount of:

o Tax
o Interest
o Penalty
o Any other sum
Within 30 days of receipt of such notice
In case of default,
o Interest u/s 220
o Penalty u/s 221

Section 156A: Modification and Revision of notice in Certain Cases

Demand notice may be overruled and modified by NCLT or Supreme Court

May be reduced or increased

Section 292B: Return, Orders, Notices, etc. deemed to be valid

Return, Orders, Notices, etc. cannot be rendered invalid merely because there exists some
mistakes in it

Section 292BB: Proceedings deemed to be valid

Where assessee appeared in any proceedings/assessments/re-assessments

And co-operated in any enquiry of the same
It shall be deemed that any notice related to such proceedings was served in time
Assessee cannot raise objection after completion of assessment that notice was not served
in time
Assessee can raise objection to notice timing before completion of assessment
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Time limit for Completing Assessment

Section Assessment Time Limit for Completion of Assessment

153(1) Scrutiny Assessment u/s 143(3) 9 months from end of Relevant AY
153(1) Best Judgement Assessment u/s 144 9 months from end of Relevant AY
153(2) Income Escaping Assessment u/s 12 months from end of FY in which notice u/s
147 148 was served
153(3) Fresh Assessment u/s 92CA where 12 months from end of FY in which order u/s 254
original assessment was cancelled is received by PCCIT/CCIT/PCIT/CIT
154(4) Where in any assessments reference Add 12 months to all above limits
was made to TPO
154(5) Effect to be given by AO/TPO 3 months from end of months in which orders
u/s 250,254,260,262 is received by
PCCIT/CCIT/PCIT/CIT
154(6)(ii) Assessment made on partner due to 12 months from end of month in which order of
assessment made on firm u/s 147 firm was passed