Amendment Text:

“Provided that order under this section shall be made within one year of issuance of show cause notice or within such extended period as the Commissioner may, for reasons to be recorded in writing, so however, such extended period shall in no case exceed ninety days. This proviso shall be applicable to a show cause notice issued on or after the first day of July, 2021:

Provided further that any period during which the proceedings are adjourned on account of a stay order or Alternative Dispute Resolution proceedings or agreed assessment proceedings under section 122D or the time taken through adjournment by the taxpayer not exceeding sixty days shall be excluded from the computation of the period specified in the first proviso.”

Explanation: The amendment prescribes a time limit of one year to finalize assessments under section 122(9) after issuing a show cause notice, extendable by a maximum of 90 days upon written justification.

Example: If a show cause notice is issued on 1st August 2025, the order must be passed by 31st July 2026. The Commissioner may extend this by 90 days, with written reasons, i.e., up to 29th October 2026.

Practical Impact & Commentary: This amendment ensures timely disposal of assessments and protects taxpayers from prolonged uncertainty. However, the clause also allows fair exclusions like stays, ADR, and limited taxpayer adjournments to be factored out. This helps maintain administrative fairness while limiting abuse of adjournment provisions. Businesses will now have a clear deadline and should prepare their documentation swiftly upon receiving a notice. It empowers both taxpayers and tax authorities with a balanced timeline framework.