Scrutiny and reopening of past returns

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This discussion explores whether a Business Journalist, who computes income under Section 44AD and has TDS deducted under Section 194JB, can face scrutiny from the AO. The AO might issue a notice under Section 143(2) for the current assessment year and reopen past returns under Section 147, especially if the declared income and TDS deductions appear inconsistent. The possibility of orders under Section 263 is also considered, though reopening is less likely if no new information has emerged.

Naveen Kumar Jain

Naveen Kumar Jain (Querist)

18 July 2026 A Business Journalist is providing editorial service to his client by editing business news and articles of interest to client's business. He is computing business income under section 44AD since editing is not part of any specified profession under 144AA. Client is deducting TDS under 194JB. His past ITR have been processed by CPC under 143(1). Can AO take a view that he should have computed income under 44ADA and issue notice under 143(2) for AY 2026-27, which return has not been processed yet, and notice under 147 for past 3 years?

Dhirajlal Rambhia

Dhirajlal Rambhia (Expert)

18 July 2026 Quite possible, as declaration of income u/s. 44AD and TDS deduction u/s. 194Jb do not coincide.

Naveen Kumar Jain

Naveen Kumar Jain (Querist)

18 July 2026 Can they also open past 3 years returns under section 147 or order under 263 for review? No new information has come to them that was not disclosed.

Dhirajlal Rambhia

Dhirajlal Rambhia (Expert)

18 July 2026 Chances are rare for earlier years.

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