VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — section 285BB and rule 114-I: what the Annual Information Statement is, and what it is not
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Statutory position — section 285BB and rule 114-I: what the Annual Information Statement is, and what it is not

The notice says an amount 'appears in your AIS' and proposes to add it. What is the AIS in law, and does an entry in it prove anything?

The notice says an amount 'appears in your AIS' and proposes to add it. What is the AIS in law, and does an entry in it prove anything?

Section 285BB requires the prescribed income-tax authority to UPLOAD, in the assessee's registered account, an annual information statement containing information which is in the possession of an income-tax authority, in the prescribed form and manner. That is the whole of the section: it is a disclosure obligation on the department, not a charging provision, not a deeming provision and not an evidentiary one. Rule 114-I lists the six heads of information that go into it and prescribes Form No. 26AS.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2020-06-01, reported as Income-tax Act 1961, s.285BB, inserted by Act No. 12 of 2020 with effect from 1 June 2020; Income-tax Rules 1962, rule 114-I and Form No. 26AS. It bears on section 285BB, section 285BA, section 285BA(4), section 285BA(6), section 133(6), section 90, section 90A of the Income Tax Act 1961, in Assessment & Scrutiny, Evidence & Burden of Proof, Reassessment & Reopening and How Tax Law Is Read matters.

Still good law. This is the statute and the rule, not a decision about them. The section text is identical on three departmental pages stamped Year 2020, Year 2021 and Year 2023, the earliest carrying the insertion footnote 'Ins. by the Act No. 12 of 2020, w.e.f. 1-6-2020'. Because no page carrying a stamp later than 2023 was located for this section, a subsequent amendment cannot be excluded. Rule 114-I carries no year stamp, as no departmental rule page does. Whether the statement now served on the compliance portal under the name 'Annual Information Statement', with its feedback mechanism and Taxpayer Information Summary, has been separately prescribed by notification since the rule was framed was NOT established on this pass, and nothing is said about it.

Why it matters

Almost every additions-from-AIS notice rests on a category error, and the section is the answer to it. Section 285BB creates no obligation on the assessee at all — it is addressed to 'the prescribed income-tax authority or the person authorised by such authority', and its only verb is 'shall upload'. Nothing in it makes an entry income, makes it correct, or shifts any burden. The information in it is, by rule 114-I(1), information already 'in his possession', drawn from the six listed heads — tax deducted or collected at source, specified financial transactions, payment of taxes, demand and refund, pending proceedings and completed proceedings — and rule 114-I(2) allows the Board to authorise the addition of information received from any other officer, authority or body, from an exchange of information under section 90 or section 90A, or from any other person. Every one of those is somebody else's report, filed by a reporting person under section 285BA and rule 114E, and every one of them can be wrong: the wrong PAN can be tagged to the right transaction, an entry can be duplicated, a joint holding can be attributed in full to one holder. The correction route runs through the reporting entity, because the reporting entity is the only person who can amend what it filed; section 285BA(6) obliges it to inform the authority of an inaccuracy within ten days of discovering it, and section 285BA(4) lets the prescribed authority intimate a defect and require rectification. That is why the practical answer to a wrong AIS entry is feedback plus a corrected statement from the reporting entity, not an explanation to the Assessing Officer. Note one point of vocabulary that matters in an appeal: rule 114-I, as it stands, prescribes Form No. 26AS for the statement it describes. The 'Annual Information Statement' the taxpayer sees on the compliance portal, with its feedback options and its Taxpayer Information Summary, is administered under departmental procedure and is not described in the rule as I read it. Do not assume that everything shown on the portal is the statutory statement.

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

Not yet CA-verified. This entry was found through the sources listed under the Sources tab, and the summary reflects what those sources say. Nobody has yet read the full judgment and signed it off. Check the source before relying on it.

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