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Order of the Board 11 August 2019

Relaxation to process time-barred returns carrying refund claims up to assessment year 2017-18

An order issued by the Central Board of Direct Taxes, as F. No. 225/194/2019/ITA-II, dated 11 August 2019. Issued under section 119.

What this is

An order under section 119 relaxing the time limit for processing returns. A return has to be processed under section 143(1) and the intimation served within the period fixed by the second proviso to that sub-section; once that period runs out the return cannot be processed at all and a genuine refund is lost through no fault of the assessee. The Board lifts that bar for a defined set of old returns carrying refund claims and fixes a fresh outer date for the processing.

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.

What it does

The Board relaxes the time-frame in the second proviso to section 143(1) and allows validly filed returns up to assessment year 2017-18 that carry a refund claim, and which remain unprocessed only because the time limit expired, to be processed now. The intimation under section 143(1) is to be sent to the assessee by 31 December 2019. The relaxation is not automatic: prior administrative approval of the Principal Chief Commissioner or Chief Commissioner concerned is required. Three classes fall outside it — returns of an earlier year selected for scrutiny and covered by section 143(1D), returns that show or are likely to result in a demand, and returns left unprocessed for reasons attributable to the assessee.

Why it was issued

Returns of earlier years sometimes go unprocessed for technical or administrative reasons. Where such a return claims a refund, the expiry of the processing period leaves the assessee holding a valid claim with no way to have it paid, and the grievance keeps returning to the department. Section 119 lets the Board relax a time limit of this kind to remove hardship, and it does so here for the older years in one stroke rather than case by case.

Who it reaches

The order runs to the Board's officers and to the processing machinery; it is their authority to process what would otherwise be time-barred. It gives the assessee no enforceable right to have his return processed, but it is a relaxation in his favour and he may press the department to act on it, since the department cannot disown its own Board's order. It decides nothing for the Tribunal or a court.

From when

Covers returns up to assessment year 2017-18. The intimation under section 143(1) must be sent by 31 December 2019.

What to watch

The relaxation stops at assessment year 2017-18 and at returns claiming a refund; a demand case gets nothing from it. The prior approval of the Pr.CCIT or CCIT is a condition and not a formality. And a return left unprocessed because the assessee did not do something — verification, for instance — is expressly outside the order.

The Board’s own words

One sentence from the document itself, reproduced as the Board wrote it. Everything else on this page is our writing about it.

Board, by virtue of its powers under section 119 of the Act, hereby relaxes the time-frame prescribed in second proviso to sub-section (1) of section 143

— the Central Board of Direct Taxes, order F. No. 225/194/2019/ITA-II, 11 August 2019. Read it in the department’s own PDF.

The provisions it turns on

The sections are the ones the document itself works on. Which section of the Income-tax Act, 2025 covers the same ground is the department’s own concordance and not our reading of it.
Under the Income-tax Act, 1961Now, in the Income-tax Act, 2025
section 143section 270
section 119section 239

Cases in this library on the same provision

These decisions turn on the same provision of the 1961 Act that this document works on. They are about the provision, not about this document: none of them is authority on what the Board meant, and a court is in any event free to read the section for itself.

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 department lists this order under 5 August 2019; the date printed on the letter reads 11 August 2019 and that is the date recorded here. The paragraph numbering and the closing paragraph were read in summary. The F. No. is transcribed from a scan that renders some separators imperfectly.