VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — section 158BC: the sixty-day notice, the two approvals, and the traps that kill a block assessment
CBDT Circulars & InstructionsCuts both wayss.158BCs.158BGs.158BBs.143(1)s.143(2)s.144Cs.153Ds.132Bs.44ABs.148

Statutory position — section 158BC: the sixty-day notice, the two approvals, and the traps that kill a block assessment

My client has a section 158BC notice for a March 2025 search. How long has he got, what happens if he files late, and is there a section 153D approval to attack?

My client has a section 158BC notice for a March 2025 search. How long has he got, what happens if he files late, and is there a section 153D approval to attack?

The notice must give a period not exceeding sixty days for the block return, and that period can be extended by a further thirty days only in the narrow audit case described in the fifth proviso. If the return goes in after the period allowed, the second proviso says in terms that it 'shall not be deemed to be a return under section 139' — so a late block return is non est, with consequences that run all the way to the notice under section 143(2). There is no section 153D approval in a block assessment; the approvals are elsewhere — section 158BC(3) requires the prior approval of the Additional or Joint Commissioner or Director BEFORE the section 158BC notice is issued, and section 158BG requires the previous approval of the same rank BEFORE the assessment order is passed.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2024-09-01, reported as Income-tax Act 1961, ss.158BC and 158BG, substituted w.e.f. 1 September 2024 by s.49 of the Finance (No. 2) Act 2024 (Act No. 15 of 2024) and amended with retrospective effect from the same date. It bears on section 158BC, section 158BG, section 158BB, section 143(1), section 143(2), section 144C, section 153D, section 132B, section 44AB, section 148 of the Income Tax Act 1961, in Search, Survey & Block Assessment, Assessment & Scrutiny, Appeals and How Tax Law Is Read matters.

Still good law. In force from 1 September 2024 as amended. Section 158BG was read on two departmental pages of different vintage (Year 2024 (No. 2) and Year 2025) printing identical text; no Year-2026 page for that section was located. No decision on the substituted section 158BC was found; the two 2026 Tribunal orders that reproduce it were both deciding cases governed by the 1995 Chapter. I did not check whether any rule prescribing the form of the block return has been notified — the form is 'as may be prescribed' and the old Form 2B is not carried forward by anything I read.

Why it matters

This is where block assessments will be won and lost, and the points are new. The first proviso deems a block return filed in time to be a return under section 139 and provides that a notice under section 143(2) 'shall thereafter be issued', which puts Hotel Blue Moon on a statutory footing for the revived Chapter — but only for a return filed in time, because the second proviso strips a late return of that status. A revised block return is barred outright by the fourth proviso. Section 143(1) is expressly switched off by section 158BC(2), so there is no intimation and no processing. The dispute resolution panel is switched off too: the proviso to section 158BC(1)(c) provides that nothing in section 144C applies to a block assessment order, so a transfer-pricing addition in a block case goes straight to a final order with no draft order and no objections. On approvals, practitioners who have spent years on section 153D — Serajuddin, Shiv Kumar Nayyar, MDLR Hotels — must be careful: section 153D has no application to a block assessment under the revived Chapter. What it has instead is two distinct approvals at two distinct points, by an Additional or Joint Commissioner or Director, and each is a separate ground. The section 158BC(3) approval precedes the notice, so its absence goes to the initiation of the proceeding; the section 158BG approval precedes the order, so its absence goes to the order. Section 158BG also fixes the rank of the assessing officer: not below Deputy or Assistant Commissioner or Deputy or Assistant Director.

Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them.

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Related

Other authorities on the same sections.