Meaning of “For any year”

The meaning of for any year under section 147 of the Income Tax Act is not defined in the act itself. But we can take guidance from decisions by various high courts. Here are excerpts of courts orders in which the Hon’ble High Court and Hon’ble Supreme Court tried to explain the meaning of for any year.

Meaning of for any year defined by court

The phrase ‘for any year’ used in section 147 of the Income Tax Act came up before various high courts as detailed under :

1. Hon’ble Supreme Court explained the meaning of ‘for any year’ while delivering judgment in First Addl. ITO Vs. H.N.S. Lyengar [1962] 44 ITR 437 (SC) as under :

Meaning: The words ‘for any year’ mean for any assessment year and not for any accounting year.

2. Hon’ble Allahabad High Court explained the meaning of ‘for any year’ while delivering judgment in Addl. CIT Vs. Hasmat Rai Raj Pal [1987] 32 TAXMAN 72/167 ITR 794 (ALL.) as under :

Meaning : The expressions ‘for that year’ and ‘for any year’ in section 147(a) refer to specific year and not ‘some year’.

Section 147 of Income Tax Act

Income escaping assessment.

147. If any income chargeable to tax, in the case of an assessee, has escaped assessment for any assessment year, the Assessing Officer may, subject to the provisions of sections 148 to 153, assess or reassess such income or recompute the loss or the depreciation allowance or any other allowance or deduction for such assessment year (hereafter in this section and in sections 148 to 153 referred to as the relevant assessment year).

Explanation.—For the purpose of assessment or reassessment or recomputation under this section, the Assessing Officer may assess or reassess the income in respect of any issue, which has escaped assessment, and such issue comes to his notice subsequently in the course of the proceedings under this section, irrespective of the fact that the provisions of section 148A have not been complied with.

In this article, you can get guidance from High Court and Supreme Court on the meaning of for any year under section 147 of the Income Tax Act.

Updated up to Finance Act 2021