Thomson Reuters International Services Private Limited v. AO: Filing modified return under Section 170A following reorganization does not grant Assessing Officer de novo scrutiny.

36. Thomson Reuters International Services Private Limited v. AO: 2026 (10) TMI 542 (Bom.):

A. Y. 2023-24: Date of order 28/09/2026:

Ss. 139, 143 and 170A of ITA 1961

Business reorganisation — Modified return of income u/s. 170A — Assessment proceedings to be carried out in respect of modified return filed by successor — Original return processed u/s. 143(1) accepting returned income — No scrutiny assessment — Time limit for issuance of scrutiny notice completed — Assessee filed modified return of income as per section 170A — Fresh scrutiny assessment proceedings initiated on the basis of modified return of income — Impermissible — As per 170A(2)(a) only limited information may be sought to verify whether correct effect has been given to the business re-organisation — De novo assessment impermissible — Subsequent notice issued by TPO u/s. 92CA(2) also held invalid and impermissible — Since fresh scrutiny itself held to be impermissible, subsequent and consequent transfer pricing proceedings are also without jurisdiction.

The assessee filed its original return of income for A. Y. 2023-24 u/s. 139 of the Income-tax Act, 1961 on 30/11/2023 declaring total income of ₹1,84,33,01,018. Intimation u/s. 143(1) was i