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of <h1>Tax Reassessment Notice Under Section 148 Invalidated Due to Limitation Period Expiry, Providing Significant Relief to Taxpayer</h1> <h3>Divay Angels Realtor Private Limited Versus Assistant Commissioner Of Income Tax, Circle 7 (1), Delhi</h3> Divay Angels Realtor Private Limited Versus Assistant Commissioner Of Income Tax, Circle 7 (1), Delhi - TMI The Delhi High Court, presided over by Hon'ble Mr. Justice Vibhu Bakhru and Hon'ble Ms. Justice Swarana Kanta Sharma, addressed a petition challenging a notice issued under Section 148 of the Income Tax Act, 1961, for the assessment year 2014-15. The petitioner argued that the notice was barred by limitation, citing the Supreme Court decision in *Union of India & Others v. Rajeev Bansal*, which clarified that notices under Section 148 could not be issued for assessment years prior to 2021-2022 if the six-year limitation period had expired. In this case, the six-year period for AY 2014-15 ended on 31.03.2021, rendering the notice issued thereafter time-barred. The court agreed with this reasoning, setting aside the impugned notice and allowing the petition.
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