#section148a

The Memorandum Explaining the Provisions of the Finance Bill, 2021 records this legislative objective clearly. It acknowledges that reassessment proceedings were a significant source of tax litigation and that the regime required simplification and rationalisation, noting that the existing procedure had resulted in avoidable disputes. The proposed system was intended to be efficient, transparent and taxpayer-friendly, while still enabling the Department to deal effectively with genuine cases of escapement of income.