The Directorate of Income Tax (Systems) released e-Verification Instruction No. 2 (i) of 2024 on March 19, 2024. This instruction pertains to initiating proceedings under section 147 of the Income Tax Act, 1961, in cases related to e-Verification. AssessingOfficers (AOs) are mandated to adhere to the guidelines outlined in the instruction, signaling a proactive approach in handling e-Verification cases.
Sub: Instructions to the AOs for initiating proceedings u/s 147 of I.T. Act, 1961 in e Verification cases-reg.
Kindly refer to the e-Verification Instruction No. 2 of 2024 circulated vide F. No.: CIT(eVerification)/2023-24/FVR/Instr./ dated March 01, 2024 on the above subject.
Vide afore mentioned Instruction, it was apprised that certain High-Risk Cases havebeen identified under e-Verification Scheme-2021 for reopening of assessment u/s 147of the Act and the respective AOs were advised to invoke the provisions of section 147of the Act and issue Notice u/s148 of the Act in such e-Verification cases accordingly.
In this connection certain query has been received from field formations with regardsto the quantum of Value at Risk (VaR) arrived at in the Final Verification Report (FVR) bythe CIT, e-Verification, as mentioned in the aforesaid Instruction. It has been conveyedthat the AOs are facing problem in viewing the FVR relating to the cases to ascertainthe quantum of Income Escapement amount/ Value at Risk.
View of all proceedings carried out by the Prescribed Authorities and documents submitted by the taxpayer during the e-Verification has been provided under eVerification module in Insight portal. The user may navigate the path Insight Portal >>Verification Module >> e-Verification (Taxpayer) >> e- Verification Scheme2021>>Verified>>Count.
The information provided to the AOs in these cases is the “Information” made available to the AO within the meaning of clause (iv) of Explanation 1 to Section 148 of the Act.For Assessment Year 2020-21, following two categories of cases have been madea vailable: –
(i) Non- updated ITR cases: No updated ITR u/s 139(8A) of the Act has been filled bythe taxpayer.
(ii) Updated ITR cases: Updated ITR u/s 139(8A) of the Act has been filled by thetaxpayer during the proceedings of e-Verification, without fully reconciling themismatch.
For Non-updated ITR cases, Value at Risk in FVR is the same as Income Escapement amount as estimated by the Prescribed Authorities in the Preliminary VerificationReport (PVR). However, in Updated ITR cases, the Value at Risk in FVR is the amount ofIncome Escapement amount as determined by the Prescribed Authorities in the PVR asreduced by any additional income shown by the assessee in Updated ITR u/s 139(8A)of the Act i.e. (Value at Risk = (Income Escapement amount determined by the PA inthe PVR – Additional income shown by the assessee in Updated ITR)}. Further, theadditional income shown by the assessee in Updated ITR u/s 139(8A) of the Act is theamount of Gross Total Income shown in Updated ITR as reduced by Gross TotalIncome shown in Original ITR i.e. (Additional income = GTI as per Updated ITR – GTI asper original ITR)
In view of the above, the respective Assessing Officers are advised to invoke provisions of section 147 of the Act and issue Notice u/s148 of the Act accordingly in such eVerification cases. To initiate proceedings u/s 147 of the Act, the path is as under:
Insight Portal >> Verification Module >> e-Verification (Taxpayer) >> High Risk – eVerification Scheme>> Under Verification>>count.
Quick Reference Guide for ‘High Risk e-Verification Scheme‘ Cases is available onInsight Portal for the assistance of the Users. For any assistance, you may raise theissue to https://ito2.systems.ev@incometax.gov.in or call helpdesk at 1800 103 4216 (Monday to Friday 9.30 AM to 6.00 PM)