CBDT Issues Instructions for Uploading Information on VRU Functionality on Insight Portal for Risk Management Strategy Implementation and Notice Issuance

The Central Board of Direct Taxes (CBDT) has published guidelines for submitting information on the Verification Report Upload (VRU) functionality on the Insight portal for the execution of a risk management plan for notice issuance.

According to the amended provisions of Section 148 of the Income-tax Act, 1961 (‘the Act’), information that has escaped assessment is defined to include two types of information: (i) information flagged in accordance with the risk management strategy formulated by the Board; and (ii) final audit objection raised by the C&AG.

In order to effectively implement the risk management strategy, the CBDT mandated that the AO select the following kinds of information relevant to AY 2015-16 and AY 2018-19, which may necessitate action under Section 148 of the Act, for uploading on the VRU functionality on the Insight site, (i) Information from any other Govt Agency/Law Enforcement Agency (ii) Information arising out of Internal Audit objection, which requires action u/s 148 of the Act (iii) Information received from any IT Authority including the assessing officer himself or herself, (iv) Information arising out of search or survey action (v) Information arising out of FT&TR references, vi) Information arising out of any order of court, appellate order, order of NCLT and/or order u/s 263/264 of the Act,having impact on income in the assessee’s case or in the case of any other assessee, (vii) Cases involving addition in any assessment year on a recurring issue of law or fact. According to Section 149(1)(b) of the Act, in specific cases where the Assessing Officer has evidence that the income escaping assessment, represented in the form of an asset, amounts to or is likely to amount to fifty lakh rupees or more, a notice can be issued beyond the three-year period but not beyond the ten-year period from the end of the relevant assessment year.

Furthermore, the notice under section 148 of the Act cannot be issued at any time in a case for the relevant assessment year beginning on or before April 1, 2021, if such notice could not have been issued at that time due to being beyond the time limit prescribed under clause (b) as it stood immediately before the proposed amendment. The term “asset” shall comprise immovable property, whether land or building or both, shares and securities, loans and advances, and deposits in a bank account, according to the explanation provided to section 149 of the Act.

In light of the foregoing, it is directed that information relevant to Assessment Year 2015-16 that needs action under Section 148 of the Act be identified and uploaded on the VRU feature on the insight portal solely in accordance with Section 149(1)(b) of the Act.

The process of identifying and uploading the information in the following categories of instances, as well as the underlying documents, must be completed by 20.12.2021.

To Read the Circular Download PDF Given Below :