Mohammed Kaleem Ullah Vs Principal Chief Commissioner of Income Tax (Telangana High Court)
Telangana High Court Upholds Rejection of Updated Return During Pending Scrutiny Assessment Mohammed Kaleem Ullah vs Principal Chief Commissioner of Income Tax & Another W.P. No. 40361 of 2025 | Telangana High Court | Decided on 05.01.2026
The Telangana High Court has clarified the scope of Section 139(8A) of the Income-tax Act, 1961, holding that an assessee cannot file an updated return once assessment proceedings have commenced or are pending. The Court dismissed a writ petition challenging an assessment order where the taxpayer sought permission to file an updated return after his case had already been selected for scrutiny under the Computer-Assisted Scrutiny Selection (CASS) system.
The judgment highlights the statutory limitations imposed by the third proviso to Section 139(8A) and reinforces that the updated return mechanism cannot be invoked after scrutiny proceedings are underway.
Introduction
In Mohammed Kaleem Ullah vs Principal Chief Commissioner of Income Tax & Another, the Telangana High Court examined whether an assessee could seek permission to file an updated return under Section 139(8A) after receiving scrutiny notices and during the pendency of assessment proceedings.
The petitioner argued that the Finance Act, 2025 had extended the time limit for filing updated returns from 24 months to 48 months and that a recent CBDT Press Release encouraging taxpayers to revise incorrect deduction claims should also benefit him.
