Section 147 of the Income Tax Act, 1961 has been amended/ substituted, by the Finance Act 2021, with effect from AY 2021-22, to provide that if any income chargeable to tax, in the case of an assessee, has escaped assessment for any assessment year, the Assessing Officer may, subject to the provisions of sections 148 to 153, assess or reassess such income, as well as any other income chargeable to tax that has escaped assessment and which comes to his notice subsequently in the course of the proceedings under this section, or re-compute the loss or the depreciation.
It may be noted that Finance Act 2021 has amended/ substituted/ inserted Sections 147, 148, 148A, 149 and 151 of the Income Tax Act 1961 with regard to reduction of Time Limit for re-opening of income tax proceedings, applicable with effect from 01/04/2021 (AY 2021-22).
Section 147: Income Escaping Assessment (as Substituted by the Finance Act 2021)
Section 147 of the Income Tax Act, 1961 has been substituted/ revised, vide Section 40 of the Finance Act, 2021, applicable w.e.f. 01/4/2021 (AY 2021-22), as under:
“If any income chargeable to tax, in the case of an assessee, has escaped assessment for any assessment year, the Assessing Officer may, subject to the provisions of sections 148 to 153, assess or reassess such income or recompute the loss or the depreciation allowance or any other allowance or deduction for such assessment year (hereafter in this section and in sections 148 to 153 referred to as the relevant assessment year).
Explanation.- For the purposes of assessment or reassessment or recomputation under this section, the Assessing Officer may assess or reassess the income in respect of any issue, which has escaped assessment, and such issue comes to his notice subsequently in the course of the proceedings under this section, irrespective of the fact that the provisions of section 148A have not been complied with.”