The assessee sought permission to file an updated return after his case had been selected for scrutiny and assessment proceedings were pending. The High Court held that, in view of clause (b) of the third proviso to section 139(8A), an updated return cannot be furnished where assessment, reassessment, recomputation or revision proceedings are pending or have been completed for the relevant assessment year. Further, the Press Release dated 23-12-2025 was applicable only to identified taxpayers who had been approached through the NUDGE campaign. Since the assessee was not an identified taxpayer and had not filed the updated return before commencement of scrutiny proceedings, rejection of his request was justified. (A.Y. 2024-25)
Mohammed Abdul Malik v. PCCIT (2026) 348 CTR 706 / 183 taxmann.com 52 (Telangana)(HC)
S. 139 : Return of income-Updated return-Updated return under section 139(8A) cannot be filed where assessment proceedings are pending-Press Release dated 23-12-2025 applicable only to identified taxpayers. [S. 139(8A), 143(2), 143(3), 144B, Art. 226]
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