Mohammed Abdul Malik Vs Principal Chief Commissioner of Income Tax (Telangana High Court)
The writ petition concerned Assessment Year 2024–2025. The petitioner challenged the assessment order dated 15.10.2025 passed under Section 143(3) read with Section 144B of the Income Tax Act, 1961, after his case was selected for scrutiny under Computer-Assisted Scrutiny Selection (CASS) pursuant to notice under Section 143(2). A notice under Section 142(1) was also issued.
In response to the notice dated 14.08.2025 under Section 142(1), the petitioner sought permission to file an updated Income Tax Return (ITR) under Section 139(8A). The Assessing Officer rejected the request and proceeded with assessment, disallowing exemptions and deductions amounting to Rs. 21,04,220/-. These included exemption under Section 10(13A) and deductions under Sections 80G, 80C, 80CCD(1B), 80D, and 80DDB. Penalty proceedings under Section 270A for under-reporting of income were initiated, and a demand notice under Section 156 was issued.
The petitioner contended that Section 139(8A), as amended by the Finance Act, 2025, permits filing of an updated return within forty-eight months from the end of the relevant assessment year, and that this period had not elapsed. Reliance was also placed on a Press Release dated 23.12.2025, under which identified taxpayers were informed via SMS and email and allowed to review and revise their returns by 31st December, 2025. It was argued that the Press Release referred to updated returns for assessment years 2021–2022 to 2024–2025 and therefore applied to his case.
