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of <h1>Section 149(1)(b) Reopening Notice Valid Within Extended Six-Year Limitation Period Due to Covid-19 Order</h1> <h3>Abha Saraf, Vikram Kumar Saraf Versus Union of India Service through the Ministry of Finance, Principle Commissioner of Income Tax, PCIT, Patna-1, Income Tax Officer, Ward No. -1 (1), Bhagalpur.</h3> Abha Saraf, Vikram Kumar Saraf Versus Union of India Service through the Ministry of Finance, Principle Commissioner of Income Tax, PCIT, Patna-1, Income ... The petitioners challenged the notice issued under Section 148 of the Income Tax Act, 1961, contending it was issued beyond the limitation period prescribed under Section 149(1)(b) prior to the 2021 amendment. Section 149(1)(b) mandates a six-year limitation from the end of the relevant assessment year when the Assessing Officer lacks incriminating books of accounts or documents, and the escaped income is Rs. 1,00,000 or more. The notice in question was issued on 01.04.2021, while the limitation period expired on 31.03.2020. However, the Court relied on the Supreme Court's suo motu order in Suo Motu Writ Petition (C) No. 3 of 2020 (In Re; (2021) 5 SCC 452), which saved the limitation period between 15.03.2020 and 28.02.2022 due to the COVID-19 pandemic. This extension applied equally to both individuals and statutory authorities. Consequently, the notice was held to be within the saved limitation period. The Court concluded there was 'absolutely no reason to interfere with the notices issued' and dismissed the writ petitions.
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