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of <h1>Reassessment notice for AY 2017-18 set aside as time-barred after six-year limitation expired on 31.03.2024 -18</h1> <h3>Felix Generics Private Limited Versus Deputy Commissioner of Income Tax Central Circle 8 Delhi & Ors.</h3> HC held the reassessment notice relating to AY 2017-18 was time-barred. The six-year period expired on 31.03.2024 and the impugned notice was issued ... Validity of reassessment proceedings - Time limit for notice u/s 149 - whether a proposed reassessment pertaining to a period prior to 01 April 2021 would sustain based on the time frames as they existed prior to the promulgation of Finance Act, 2021? - scope of new regime - HELD THAT:- In the present case, the period of six years for the relevant assessment year 2017-18 expired on 31.03.2024. The impugned notice has been issued thereafter, and the same is thus barred by limitation. Respondent is unable to counter the said submissions. The impugned notice is set aside. Petition challenged a notice dated 31.08.2024 issued under Section 148 (and related Section 148A(b)/148A(d) steps) for assessment year 2017-18. Reliance was placed on the Supreme Court in Union of India v. Rajeev Bansal, including that 'no notice under Section 148 of the new regime can be issued at any time for an assessment year beginning on or before 1 April 2021' and 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.' The court observed that the six-year period for AY 2017-18 expired on 31.03.2024, so the impugned notice dated 31.08.2024 was 'barred by limitation.' Respondent did not controvert the submission. The impugned notice was therefore set aside and the petition allowed. Pending applications disposed of.
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