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of <h1>Landmark Tax Notice Invalidation: Section 148 Notice Quashed Beyond Six-Year Limitation Period</h1> <h3>NEERA GUPTA Versus ITO, WARD 46 (4), DELHI</h3> HC invalidated a tax notice under Section 148 for AY 2015-16, finding it time-barred. Following SC precedent, the court ruled that notices cannot be ... Validity of reassessment proceedings as barred by limitation - period of six years from the end of the relevant assessment year determination - HELD THAT:- In the present case, the period of six years from the end of the relevant (AY) 2015-16 expired on 31.03.2022. The impugned notice has been issued thereafter, and the same is thus barred by limitation. Thus the impugned notice is set aside. Decided in favour of assessee. The Delhi High Court, in a petition challenging a notice dated 16.10.2024 issued under Section 148 of the Income Tax Act, 1961 for AY 2015-16, held the notice barred by limitation. The Court relied on the Supreme Court's ruling in Union of India & Ors v. Rajeev Bansal (2024 SCC OnLine SC 2693), emphasizing that 'a notice under Section 148 of the new regime cannot be issued if the period of six years from the end of the relevant assessment year has expired at the time of issuance of the notice.' Since the six-year period for AY 2015-16 expired on 31.03.2022, the impugned notice issued thereafter was invalid. The Court accordingly set aside the notice and allowed the petition.
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