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CBDT issues Interim Action Plan for FY 2020-21 to direct no Adverse Communication amid COVID-19


CBDT has issued Interim Action Plan for the First Quarter (April 2020 to June 2020) of FY 2020-21 dated 8 May 2020 and directs income tax department not to issue any adverse communication to the assessees during COVID-19 pandemic times till fresh guidelines are issued by the Board in this regard.

Every year CBDT issues a comprehensive Central Action Plan for the first quarter of the financial year giving certain targets to the field formation in the Key Results Area (KRA).

However, due to the unprecedented situation arising out of COVID-19 pandemic this year, a relatively short Interim Action Plan for the first quarter of FY 2020-21 is issued.

The main emphasis of this Interim Action Plan is in-house cleaning and preparedness of the work when normalcy returns.

A Central Action Plan is a vision document which is released by the CBDT directing the income tax department's officers for actions to be taken in ceratin KRAs. It includes collection target of arrear demand, reduction of arrear demands, litigation management including disposal of appeals at CIT(A) level, passing of appeal effect orders, disposal of prosecution cases, various tasks related to scrutiny assessments, surveys, disposals of various nature of applications by the assessees, preparation of various reports, settlement of Audit objections and many more. The time frame is also prescribed for executing the actions envisaged in the Central Action Plan.

However, due to lockdown situation all over the country continuing since the beginning of this financial year 2020-21 amid COVID-19 pandemic, a short Central Action Plan or Interim Action Plan for the First Quarter (April, 2020 to June, 2020) of FY 2020-21 dated 8 May 2020 has been issued which primarily aims to preparedness for the work when normalcy returns.

The main highlight of the Interim Action Plan for the First Quarter (April, 2020 to June, 2020) of FY 2020-21 is that it has debarred the income tax department from issuing any communication (notices, etc.) to the assessees having adverse effect on the assessee during the first quarter of the Financial Year 2020-21 till 30.06.2020. The Board will issue fresh guidelines in this regard after June 30, which seems will depend on the then prevailing situation.

‘Communication to the assessees’ generally refers to scrutiny notices, notices for compliances, intimation for adjustments, any show-cause notices, etc. in income-tax perspective.

In this context, it has been seen that CPC is issuing notices u/s 245 before processing the return of income u/s 143(1) in any refund is found to be due to the assessee. The income tax department has appealed that assessees should respond to the notices promptly so that refund can be issued expeditiously as the government has announced to release all the pending refunds up to Rs. 5 Lakh during this tough times.

Thus, the restriction primarily aims to restrict the department from issuing any scrutiny assessment notices or show cause notices or similar notices to avoid any panic among the taxpayers.

Further, the Interim Action Plan requires the income tax department to identify the cases where notices u/s 148 can be issued by 30.06.2020 but debarred the department from issuing any notice u/s 148 till further communication from the CBDT in this regard. It has to be noted that the Taxation and other Laws (Relaxation of Certain Provisions) Ordinance, 2020 has extended the time limit for issuance of notices from March 31, 2020 to June 30, 2020.

Some days ago the IRS Officers Association issued a report called FORCE and suggested various harsh and hard-hitting measures to boost revenue collection by increasing the surcharges and cess and by introducing some repealed taxes. The government has rejected such reports outrightly and denied its role in the making of these reports. Disciplinary actions have been initiated in the case against some officers. The tax department faced widespread criticism on such a report prepared by a group of IRS officers since it had created panic among the taxpayers at a time when India is already going through a difficult economic situation.

Final settlement of Revenue and Internal Audit Objections in 75% of cases where the objections were raised till 31.03.2019 and 50% of objections raised up to 31.03.2020.

In search cases, the eligible cases shall be transferred to Central charge within the same city. If any inter-city transfer is involved, the same should be kept in hold.

The income-tax officers are required to dispose of rectification applications filed by the assessees by June 30, 2020. Further, appeal effect orders shall be passed in all eligible cases.

The plan further directs for disposal of applications for grant of registration under section 12AA or 80G of the Income Tax Act, 1961 and disposal of all condonation petitions related to delay in filing of Form 10 and Form 10B by June 30, 2020. CBDT has extended the date of compliances related to switching to the new registration procedure and others - as introduced by the Finance Act, 2020, from June 1 to October 1, 2020.

All CPGRAMS grievances older than 30 days shall be disposed of.

In all the above cases, the time frame given is June 30, 2020.

Several other measures or actions have been directed in the Interim Action Plan.

The Key Result Areas and the prescribed time frame as mentioned in the Interim Action Plan for the First Quarter (April 2020 to June 2020) of FY 2020-21 dated 8 May 2020 are given as under:

Key Result Areas (KRA)
Time Frame
A. Assessment Related Work:
Identification and preparedness regarding issuance of notice u/s 148 in all eligible P-Z category cases, made available by Directorate of Systems in the AIMS module of ITBA, as mentioned in Board's letter F. No. 225/85/2020/ITA-11 dated 19th March, 2020. However, these notices u/s 148 are to be issued only after getting fresh communication from the Board in this regard.

Uploading on System the manual orders issued u/s 147 and 263
Audit Objections:
Identification and preparedness regarding:
(a)Final settlement in 75% Major and Minor Revenue and Internal Audit Objections raised up to 31.03.2019.
(b)Final settlement of at least 50% of Major and 75% of Minor Revenue and Internal Audit Objections (separately) raised up to 31.03. 2020.
Central Charges:
(a) Centralization in all eligible cases (by passing order u/s 127)where search took place in FY 2019-20) in the Central charges. However, inter-city transfer of cases should be kept on hold.
(b) Decentralization of cases to be completed as per existing instructions by the Central charges.
B. Demand Related Work: (including International Taxation, Central, Exemption and TDS  Charges)
Preparedness for disposal of applications u/s 154 filed by the assessees and giving appeal effects in all eligible cases.

Checking of all demands PAN -wise and Year-wise from Systems, AST/TMS or Manual demand wherever remaining and removal of all duplicate demands.
Reconciliation of brought forward cases (as on 01.04.2020) of TDS reported by AINs with payment through OLTAS by State AGs based on e ort available on TRACES portal for TDS units. 
C. Exemptions Units
Cases falling under the jurisdiction of CCIT (Exemptions) which are still lying at incorrect jurisdictions to be identified and transferred to respective CsIT (Exemptions). However, inter-city transfer of cases should be kept on hold.

Disposal of all applications for grant of registration under section 12AA or 80G of the Income- tax Act, 1961 received up to 31st March, 2020
Disposal of all petitions filed up to 31st March, 2020 seeking condonation 30.06.2020 of delay in filing Form 10 & 10B
Completion of consequential rectification by Assessing Officers in all cases wherein condonation has been allowed by the CIT for delay in filing Form 10 or 10B
D. Pr. Chief Commissioners / Chief Commissioners and Pr. Commissioners / Commissioners:
Completion of all the inspection/reviews for FY 2019-20

Disposal of at-least 25% compounding applications pending as on 01.04.2020
The annual exercise of updating Asset Register (as on 31.03.2020)
Identification and withdrawal of non-prosecutable appeals by the collegium of CCsIT/ DGsIT
Preparation and updating of PD Account in ITBA by Pr. CITs for all transactions up to 31.03.2020 and onwards
Disposal of all CPGRAMS grievance older than 30 days.
All rent related proposals (revision of rent or new lease agreements) to be submitted after completing all formalities to the Board
Holding of all DPCs at all grades (Group-B & C) within the cadre control of the Pr. CCIT and issue of orders.
Read the Interim Action Plan for FY 2020-21 for the first quarter.

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