02 August 2025
Great question! Here’s the clarification on **Section 142(1) of the Income Tax Act**:
* **Section 142(1)** empowers the Assessing Officer (AO) to issue a notice to the taxpayer **to file a return** or **to produce books of account or documents**. * **There is NO specific time limit mentioned in Section 142(1) itself** for issuing such a notice. * However, the AO's powers to **examine books of account** or **initiate assessment proceedings** are subject to the **time limits prescribed under the Act** (mostly under Section 153 and 153A).
**Now, about the 3 years limit:**
* Normally, the AO can reopen assessments or call for books **within 3 years from the end of the relevant assessment year**. * For routine scrutiny or assessments under Section 143(3), the limit is 3 years. * For reassessment under Section 147, it's generally 3 years, except in cases of serious tax evasion (up to 10 years).
**Putting it together:**
* While the notice under Section 142(1) **can technically be issued anytime** (no strict limit), * The **right to initiate or complete assessment based on that notice is limited by the 3-year bar** (or extended time limits if applicable). * So practically, after 3 years, AO’s ability to proceed meaningfully based on Section 142 notices is limited.
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**Summary:**
| Aspect | Time Limit | | ----------------------------- | ------------------------------------- | | Issuance of notice u/s 142(1) | No explicit time limit | | Assessment / scrutiny action | Within 3 years from end of AY (usual) |