Section 249 is the substantive equivalent of 1961 s. 132(13) -- the provision dealing with reasons not to be disclosed within Chapter XIV (Tax Administration) framework. Critical for operational tax administration; defines authority…
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ITA 2025 · Section 249
Section 249 — - REASONS NOT TO BE DISCLOSED
Section 249 is the substantive equivalent of 1961 s. 132(13) -- the provision dealing with reasons not to be disclosed within Chapter XIV (Tax Administration) framework. Critical for operational tax administration; defines authority structure / powers / procedures / safeguards. Practitioner relevance: every assessment / verification / compliance interaction with tax authorities involves these provisions.
STATUTORY ARCHITECTURE: Reasons not to be disclosed is part of the foundational tax administration framework under Chapter XIV. The provision establishes the legal basis for reasons not to be disclosed and operational mechanics. Key practitioner aspects: (i) authority hierarchy clarity; (ii) procedural compliance; (iii) constitutional safeguards (Articles 14, 21 -- equality before law / personal liberty); (iv) appellate / writ remedy availability for procedural violations. The 2025 Act preserves the substantive 1961 framework while modernising terminology and incorporating post-2020 faceless administration architecture.
PRACTITIONER RELEVANCE
Compliance with this provision is mandatory for any tax administration interaction. Procedural violations may give rise to writ jurisdiction under Articles 226 / 32 of the Constitution. Assessment-level review through CIT(A) / NFAC / ITAT / High Court appellate routes available. CBDT circulars / instructions provide operational guidance.
CROSS-REFERENCES