Applied learning18 practical cases
Case 1: Information mismatch inquiry
Section: 268
Facts: An assessment file raises inquiry before assessment. The taxpayer prepares a jurisdiction note, issue-wise evidence index, computation reconciliation and limitation calendar.
Approach: Respond issue-wise, reconcile submissions to books and return, and control third-party data. Special audit requires the statutory process and report forms.
Control: Test notice, sanction, service and limitation.; Respond issue-wise with reconciled evidence.; Review order, demand, credit and remedy immediately on receipt.
Case 2: Special audit direction
Section: 268
Facts: An assessment file raises inquiry before assessment. The taxpayer prepares a jurisdiction note, issue-wise evidence index, computation reconciliation and limitation calendar.
Approach: Respond issue-wise, reconcile submissions to books and return, and control third-party data. Special audit requires the statutory process and report forms.
Control: Test notice, sanction, service and limitation.; Respond issue-wise with reconciled evidence.; Review order, demand, credit and remedy immediately on receipt.
Case 3: Valuation Officer reference
Section: 269
Facts: A taxpayer encounters an issue concerning estimation of value of assets by valuation officer. The working paper maps the facts, statutory conditions and prescribed procedure before any position is taken.
Approach: Identify the person, event, period, conditions, authority, evidence and consequence before applying the provision.
Control: Record the applicable person, event and tax year.; Link every conclusion to statutory conditions and primary evidence.; Track prescribed form, authority, limitation and downstream consequence.
Case 4: Automated processing adjustment
Section: 270
Facts: An assessment file raises assessment. The taxpayer prepares a jurisdiction note, issue-wise evidence index, computation reconciliation and limitation calendar.
Approach: Separate automated processing from scrutiny. Track the exact adjustment power, notice validity, evidence, hearing and final computation.
Control: Test notice, sanction, service and limitation.; Respond issue-wise with reconciled evidence.; Review order, demand, credit and remedy immediately on receipt.
Case 5: Scrutiny assessment evidence
Section: 270
Facts: An assessment file raises assessment. The taxpayer prepares a jurisdiction note, issue-wise evidence index, computation reconciliation and limitation calendar.
Approach: Separate automated processing from scrutiny. Track the exact adjustment power, notice validity, evidence, hearing and final computation.
Control: Test notice, sanction, service and limitation.; Respond issue-wise with reconciled evidence.; Review order, demand, credit and remedy immediately on receipt.
Case 6: Best-judgment estimate
Section: 271
Facts: An assessment file raises best judgment assessment. The taxpayer prepares a jurisdiction note, issue-wise evidence index, computation reconciliation and limitation calendar.
Approach: Best judgment is not arbitrary judgment. Build the record, explain non-compliance and challenge unsupported estimates with contemporaneous evidence.
Control: Test notice, sanction, service and limitation.; Respond issue-wise with reconciled evidence.; Review order, demand, credit and remedy immediately on receipt.
Case 7: Binding direction by Joint Commissioner
Section: 272
Facts: A taxpayer encounters an issue concerning power of joint commissioner to issue directions in certain cases. The working paper maps the facts, statutory conditions and prescribed procedure before any position is taken.
Approach: Identify the person, event, period, conditions, authority, evidence and consequence before applying the provision.
Control: Record the applicable person, event and tax year.; Link every conclusion to statutory conditions and primary evidence.; Track prescribed form, authority, limitation and downstream consequence.
Case 8: Faceless assessment hearing request
Section: 273
Facts: An assessment file raises faceless assessment. The taxpayer prepares a jurisdiction note, issue-wise evidence index, computation reconciliation and limitation calendar.
Approach: Maintain a portal calendar, document index, response acknowledgements and video-hearing file. Do not assume physical jurisdiction rules disappear.
Control: Test notice, sanction, service and limitation.; Respond issue-wise with reconciled evidence.; Review order, demand, credit and remedy immediately on receipt.
Case 9: Reference involving impermissible arrangement
Section: 274
Facts: A taxpayer encounters an issue concerning reference to principal commissioner or commissioner in certain cases. The working paper maps the facts, statutory conditions and prescribed procedure before any position is taken.
Approach: Identify the person, event, period, conditions, authority, evidence and consequence before applying the provision.
Control: Record the applicable person, event and tax year.; Link every conclusion to statutory conditions and primary evidence.; Track prescribed form, authority, limitation and downstream consequence.
Case 10: Draft order before DRP
Section: 275
Facts: An assessment file raises reference to dispute resolution panel. The taxpayer prepares a jurisdiction note, issue-wise evidence index, computation reconciliation and limitation calendar.
Approach: DRP is a time-bound pre-demand route. Identify eligibility, draft-order date, objection deadline, issues and supporting evidence immediately.
Control: Test notice, sanction, service and limitation.; Respond issue-wise with reconciled evidence.; Review order, demand, credit and remedy immediately on receipt.
Case 11: Rejected accounting method
Section: 276
Facts: A taxpayer encounters an issue concerning method of accounting. The working paper maps the facts, statutory conditions and prescribed procedure before any position is taken.
Approach: Identify the person, event, period, conditions, authority, evidence and consequence before applying the provision.
Control: Record the applicable person, event and tax year.; Link every conclusion to statutory conditions and primary evidence.; Track prescribed form, authority, limitation and downstream consequence.
Case 12: Inventory valuation method
Section: 277
Facts: A taxpayer encounters an issue concerning method of accounting in certain cases. The working paper maps the facts, statutory conditions and prescribed procedure before any position is taken.
Approach: Identify the person, event, period, conditions, authority, evidence and consequence before applying the provision.
Control: Record the applicable person, event and tax year.; Link every conclusion to statutory conditions and primary evidence.; Track prescribed form, authority, limitation and downstream consequence.
Case 13: Construction-contract income recognition
Section: 278
Facts: A special liability applies to one income bucket. The computation separately identifies that bucket and prevents double taxation or duplicate credit.
Approach: Reconcile the taxpayer, tax base, rate, deductions, credits, timing, reporting and recovery provisions before computing liability.
Control: Record the applicable person, event and tax year.; Link every conclusion to statutory conditions and primary evidence.; Track prescribed form, authority, limitation and downstream consequence.
Case 14: Escaped-income information
Section: 279
Facts: An assessment file raises income escaping assessment. The taxpayer prepares a jurisdiction note, issue-wise evidence index, computation reconciliation and limitation calendar.
Approach: Start with jurisdiction: information, escaped-income threshold, limitation, pre-notice procedure and sanction. Merits come after notice validity.
Control: Test notice, sanction, service and limitation.; Respond issue-wise with reconciled evidence.; Review order, demand, credit and remedy immediately on receipt.
Case 15: Reassessment notice
Section: 280
Facts: An assessment proposes a mismatch addition. The taxpayer reconciles return, books, third-party statement and supporting vouchers before the hearing.
Approach: Build a notice-to-issue matrix covering jurisdiction, limitation, evidence, hearing, computation and final order service.
Control: Record the applicable person, event and tax year.; Link every conclusion to statutory conditions and primary evidence.; Track prescribed form, authority, limitation and downstream consequence.
Case 16: Pre-notice response
Section: 281
Facts: An assessment file raises procedure before issuance of notice under section 280. The taxpayer prepares a jurisdiction note, issue-wise evidence index, computation reconciliation and limitation calendar.
Approach: Treat the pre-notice stage as a jurisdictional record. Ask for relied-on information, answer both law and facts, and preserve service dates.
Control: Test notice, sanction, service and limitation.; Respond issue-wise with reconciled evidence.; Review order, demand, credit and remedy immediately on receipt.
Case 17: Reassessment limitation
Section: 282
Facts: A taxpayer encounters an issue concerning time limit for notices under sections 280 and 281. The working paper maps the facts, statutory conditions and prescribed procedure before any position is taken.
Approach: Identify the person, event, period, conditions, authority, evidence and consequence before applying the provision.
Control: Record the applicable person, event and tax year.; Link every conclusion to statutory conditions and primary evidence.; Track prescribed form, authority, limitation and downstream consequence.
Case 18: Search block return
Section: 294
Facts: An assessment file raises procedure for block assessment. The taxpayer prepares a jurisdiction note, issue-wise evidence index, computation reconciliation and limitation calendar.
Approach: Use ITR-BN, a seized-material index, issue matrix and year/period reconciliation. Every addition should link to block evidence.
Control: Test notice, sanction, service and limitation.; Respond issue-wise with reconciled evidence.; Review order, demand, credit and remedy immediately on receipt.
Professional Q&A36 questions
1. What is the core purpose of section 268?
Respond issue-wise, reconcile submissions to books and return, and control third-party data. Special audit requires the statutory process and report forms.
Sections: 268
2. What is the core purpose of section 269?
Identify the person, event, period, conditions, authority, evidence and consequence before applying the provision.
Sections: 269
3. What is the core purpose of section 270?
Separate automated processing from scrutiny. Track the exact adjustment power, notice validity, evidence, hearing and final computation.
Sections: 270
4. What is the core purpose of section 271?
Best judgment is not arbitrary judgment. Build the record, explain non-compliance and challenge unsupported estimates with contemporaneous evidence.
Sections: 271
5. What is the core purpose of section 272?
Identify the person, event, period, conditions, authority, evidence and consequence before applying the provision.
Sections: 272
6. What is the core purpose of section 273?
Maintain a portal calendar, document index, response acknowledgements and video-hearing file. Do not assume physical jurisdiction rules disappear.
Sections: 273
7. What is the core purpose of section 274?
Identify the person, event, period, conditions, authority, evidence and consequence before applying the provision.
Sections: 274
8. What is the core purpose of section 275?
DRP is a time-bound pre-demand route. Identify eligibility, draft-order date, objection deadline, issues and supporting evidence immediately.
Sections: 275
9. What is the core purpose of section 276?
Identify the person, event, period, conditions, authority, evidence and consequence before applying the provision.
Sections: 276
10. What is the core purpose of section 277?
Identify the person, event, period, conditions, authority, evidence and consequence before applying the provision.
Sections: 277
11. What is the core purpose of section 278?
Reconcile the taxpayer, tax base, rate, deductions, credits, timing, reporting and recovery provisions before computing liability.
Sections: 278
12. What is the core purpose of section 279?
Start with jurisdiction: information, escaped-income threshold, limitation, pre-notice procedure and sanction. Merits come after notice validity.
Sections: 279
13. What is the core purpose of section 280?
Build a notice-to-issue matrix covering jurisdiction, limitation, evidence, hearing, computation and final order service.
Sections: 280
14. What is the core purpose of section 281?
Treat the pre-notice stage as a jurisdictional record. Ask for relied-on information, answer both law and facts, and preserve service dates.
Sections: 281
15. What is the core purpose of section 282?
Identify the person, event, period, conditions, authority, evidence and consequence before applying the provision.
Sections: 282
16. What is the core purpose of section 283?
Identify the appealable order, correct forum, service date, fee, form, grounds, stay requirement and paper-book record.
Sections: 283
17. What is the core purpose of section 284?
Identify the person, event, period, conditions, authority, evidence and consequence before applying the provision.
Sections: 284
18. What is the core purpose of section 285?
Identify the person, event, period, conditions, authority, evidence and consequence before applying the provision.
Sections: 285
19. What is the core purpose of section 286?
Prepare a limitation worksheet with tax year, proceeding type, notice date, exclusions, court stays, references and final deadline.
Sections: 286
20. What is the core purpose of section 287?
Rectification is for evident error, not a debatable re-hearing. Identify the record, mistake, computation effect and limitation date.
Sections: 287
21. What is the core purpose of section 288?
Identify the person, event, period, conditions, authority, evidence and consequence before applying the provision.
Sections: 288
22. What is the core purpose of section 289?
Identify the person, event, period, conditions, authority, evidence and consequence before applying the provision.
Sections: 289
23. What is the core purpose of section 290?
Identify the person, event, period, conditions, authority, evidence and consequence before applying the provision.
Sections: 290
24. What is the core purpose of section 291?
Identify the person, event, period, conditions, authority, evidence and consequence before applying the provision.
Sections: 291
25. Is an intimation the same as scrutiny assessment?
No. Processing adjustments and scrutiny assessment operate through different statutory routes.
Sections: Chapter XVI
26. Can best judgment be arbitrary?
No. It must be a rational estimate grounded in available material and statutory procedure.
Sections: Chapter XVI
27. What is the DRP route?
A time-bound objection route against an eligible draft order before the final assessment and demand.
Sections: Chapter XVI
28. What should a reassessment challenge test first?
Information, escaped-income basis, pre-notice procedure, limitation, sanction, service and jurisdiction.
Sections: Chapter XVI
29. Can rectification decide a debatable legal issue?
Ordinarily no. It is for an apparent mistake in the relevant record.
Sections: Chapter XVI
30. What does a limitation worksheet contain?
Tax year, proceeding, notice dates, statutory period, exclusions, stays, references and final deadline.
Sections: Chapter XVI
31. Why reconcile third-party statements early?
Mismatch data often triggers inquiry or adjustment and may require source-system correction.
Sections: Chapter XVI
32. What is the role of a Valuation Officer?
To estimate value within the statutory reference and Rule 173 jurisdiction framework.
Sections: Chapter XVI
33. Does faceless assessment remove the need for evidence indexing?
No. Clear electronic indexing is even more important.
Sections: Chapter XVI
34. How is block income different?
It is search-related undisclosed income computed for the statutory block period under the special code.
Sections: Chapter XVI
35. What form is used for block return?
ITR-BN under Rule 180.
Sections: Chapter XVI
36. What follows an adverse assessment order?
Immediate review of computation, credits, demand, penalty exposure, rectification, appeal and stay.
Sections: Chapter XVI