The Central Board of Direct Taxes (CBDT), Department of Revenue, Ministry of Finance, issued a communication dated 02.02.2026 regarding clarificatory amendments proposed in the Finance Bill, 2026.
The Finance Bill, 2026 was introduced in the Lok Sabha on 1 February 2026. In the Budget Speech, the Hon’ble Finance Minister stated that certain legal issues have resulted in differing court judgments. These issues relate to:
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Time limits for assessment after Dispute Resolution Panel proceedings
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Time limits for Transfer Pricing Officer orders
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Document Identification Number (DIN)
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Issuance of reassessment notices by the Jurisdictional Assessing Officer
To provide certainty and clarity, amendments in the nature of clarifications have been proposed in both the Income Tax Act, 1961 and the Income Tax Act, 2025.
Specifically, amendments are proposed to sections 92CA, 144C, 153, and 153B of the Income Tax Act, 1961, along with insertion of new sections 147A and 292BA. Relevant extracts of the Finance Bill, 2026 have been enclosed as an annexure for reference.
The CBDT has directed that instructions be issued to Commissioners of Income Tax (Departmental Representatives), Senior Departmental Representatives, and counsels representing the Department before High Courts and the Income Tax Appellate Tribunal (ITAT) to seek adjournments in matters involving the issues covered by these proposed amendments.
The communication was issued with the approval of Member (A&J), CBDT.
F. No. 279/Misc/M-13/2026-ITJ
Government of India
Ministry of Finance
Department of Revenue
Central Board of Direct Taxes
Income Tax (Judicial)
Room No. 8, 5th Floor
Jeevan Deep Building
Parliament Street, New Delhi
Dated: 02.2026
Dated: 02.02.2026
To,
All the Principal Chief Commissioners of Income Tax
Sir/Madam,
Subject: – Amendments in the nature of clarifications in the Income Tax Act,1961 proposed by the Finance Bill, 2026-reg.
Kindly refer to the above-mentioned subject.
2. The Finance Bill, 2026 was introduced in the Lok Sabha on 1st February 2026 by the Hon’ble Finance Minister. In her Budget Speech, as part of rationalisation of Direct Tax provisions, the Hon’ble Finance Minister proposed certain amendments in the nature of clarifications, stating as follows:
“There are certain legal issues in which there are differing judgements of courts. These relate to time-limit for assessment after Dispute Resolution Panel proceedings, time-limit for Transfer Pricing Officer order, Document Identification Number and issuance of notice for re-assessment by Jurisdictional Assessing Officer. In this regard, it is proposed to clarify these issues in the Income Tax Act, 1961 and Income Tax Act, 2025 to provide certainty to provisions.”
3. Accordingly, amendments to sections 92CA, 144C, 153 and 153B, along with insertion of new sections 147A and 292BA in the Income Tax Act, 1961 have been proposed through the Finance Bill, 2026. The relevant pages of the Finance bill, 2026 are enclosed as Annexure to this letter for ready reference.
4. In light of the above, I am directed to state that directions may be issued to all the CsIT (DR)/ Sr. (DR) and the counsels representing the Income Tax Department before the Hon’ble High Courts and the ITAT benches in your region to seek adjournment in the appeals/writs involving the issues pertaining to aforementioned amendments.
5. This issues with the approval of Member (A&J), CBDT.
End: As above.
Yours Faithfully,
(Divya Chaudhary)
Deputy secretary (ITJ)
