An order issued by the Central Board of Direct Taxes, as F. No. Pr.CCIT(NeAC)/2019-20, dated 24 December 2019.
A short document from the Principal Chief Commissioner of Income-tax, National e-Assessment Centre, extending the time to answer notices already issued by that Centre. Faceless assessment under the E-assessment Scheme, 2019 was in its first season, and notices under section 142(1) were going out with short compliance dates over the year end. This document pushes the response date out for every such notice issued up to 24.12.2019.
This is an order of the Board. An order is issued under a power the Act itself gives the Board — most often section 119, which lets it direct its own officers and, in the cases the section names, relax a requirement. Read the enabling words before deciding how far it reaches: the power is administrative, and it cannot rewrite the charge.
The Centre states that, with a view to providing relief to taxpayers and tax professionals and to facilitate compliance in e-assessment proceedings under the E-assessment Scheme, 2019, the time limit for filing a response to notices under section 142(1) of the Income-tax Act issued up to 24.12.2019 by the National e-Assessment Centre is extended up to 10.01.2020, or the time given in such notices, whichever is later. The extension is general within its class — it covers every section 142(1) notice issued by the Centre up to that date — and it can never shorten anything, because a notice already allowing longer keeps its own date.
The first year of faceless assessment coincided with the year end, and notices under section 142(1) were issued in volume with compliance dates falling in the last week of December. Assessees and their representatives could not collect and upload the material in time, and a failure to answer a notice under section 142(1) carries consequences. Rather than deal with extensions case by case, the Centre extended the date for the whole class at once.
The extension binds the Centre and its units: a response filed by 10.01.2020, or by the date in the notice if later, is in time and cannot be treated as a default. The assessee takes the benefit and need do nothing to claim it. It does not bind the Tribunal or a court, but the department can be held to it if a best-judgment assessment or a penalty is later raised.
For notices under section 142(1) issued by the National e-Assessment Centre up to 24.12.2019. The response date becomes 10.01.2020, or the time given in the notice, whichever is later.
The extension is limited by both issuing authority and date — notices from the National e-Assessment Centre, issued up to 24.12.2019. A notice from a jurisdictional officer, or one issued after that date, falls outside it. And because the extension is to the later of two dates, read the notice itself before assuming 10.01.2020 is the operative date.
the time limit for filing of response to notices under section 142(1) of the Income-tax Act issued up to 24.12.2019 by the National e-Assessment Centre is extended up to 10.01.2020 or time given in such notices, whichever is later.
— the Central Board of Direct Taxes, order F. No. Pr.CCIT(NeAC)/2019-20, 24 December 2019. Read it in the department’s own PDF.
| Under the Income-tax Act, 1961 | Now, in the Income-tax Act, 2025 |
|---|---|
| section 142 | section 268 |
| section 143 | section 270 |
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What here is the Board’s and what is ours. The document is the Central Board of Direct Taxes’ own. Its number, its date and the words quoted above are reproduced from the Board’s own PDF, which is here. Everything else on this page is ours: the plain-English account of what the document is and what it does, the reading of which provision it turns on, the note on what to watch, and the choice of cases. Where our account and the document part, the document governs.
An order of the Board binds the department, not you and not a court. The Board writes to its own officers. An assessee may hold the department to an order or an instruction that helps him; the department cannot hold an assessee to one that hurts him, and the Tribunal and the courts decide the law for themselves. This is the most common mistake made with this material, and it is worth making twice: a direction of the Board is not a section of the Act.
What we could not settle. The running number after 'Pr.CCIT(NeAC)/2019-20' was not legible in the scan. The document states no provision under which the extension is made.