The Directorate of Income Tax (Systems) has recently issued e-Verification Instruction No. 2 (i) of 2024 on March 19, 2024, directing Assessing Officers (AO’s) to take action under section 147 of the Income Tax Act, 1961, in e-Verification cases.
This instruction, referenced as e-Verification Instruction No. 2 of 2024 in a communication dated March 01, 2024, highlights the identification of High-Risk Cases under the e-Verification Scheme-2021 for reopening assessments under section 147 of the Act. It advises AOs to use section 147 and issue Notice u/s 148 accordingly in such e-Verification cases.
Field formations have raised queries regarding the Value at Risk (VaR) determined in the Final Verification Report (FVR) by the CIT, e-Verification, as mentioned in the aforementioned instruction. AOs have reported difficulties in accessing the FVR to determine the Income Escapement amount/ Value at Risk.
All proceedings and documents submitted by taxpayers during e-Verification are available in the e-Verification module in the Insight portal. Users can access this information by navigating through Insight Portal >> Verification Module >> e-Verification (Taxpayer) >> e-Verification Scheme 2021 >> Verified >> Count.
The information provided to AOs in these cases falls under the definition of “Information” within the meaning of clause (iv) of Explanation 1 to Section 148 of the Act. For Assessment Year 2020-21, two categories of cases have been identified:
1. Non-updated ITR cases: Where no updated ITR u/s 139(8A) of the Act has been filed by the taxpayer.
2. Updated ITR cases: Where an updated ITR u/s 139(8A) of the Act has been filed during e-Verification proceedings without fully reconciling the mismatch.
In Non-updated ITR cases, the Value at Risk in FVR aligns with the Income Escapement amount estimated by the Prescribed Authorities in the Preliminary Verification Report (PVR). However, in Updated ITR cases, the Value at Risk in FVR is calculated as the difference between the Income Escapement amount determined by the Prescribed Authorities in the PVR and any additional income declared by the assessee in the Updated ITR u/s 139(8A) of the Act.
AOs are advised to follow the path: Insight Portal >> Verification Module >> e-Verification (Taxpayer) >> High Risk – e-Verification Scheme >> Under Verification >> count to initiate proceedings u/s 147 of the Act in such e-Verification cases. A Quick Reference Guide for ‘High Risk e-Verification Scheme’ Cases is available on the Insight Portal for user assistance. For further support, issues can be raised at http://ito2.systems.ev@incometax.gov.in or by calling the helpdesk at 1800 103 4216 (Monday to Friday 9.30 AM to 6.00 PM).
Subscribe Taxscan Premium to view the JudgmentSupport our journalism by subscribing to Taxscan premium. Follow us on Telegram for quick updates
