Income tax reassessment notice timing: Covid-era time exclusion saves s.147/s.148 limitation; Principal Commissioner's s.151(i) sanction upheld. The dominant issue was whether reassessment proceedings under s.147 could be initiated within limitation by applying statutory saving/exclusion of time, ...
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Income tax reassessment notice timing: Covid-era time exclusion saves s.147/s.148 limitation; Principal Commissioner's s.151(i) sanction upheld.
The dominant issue was whether reassessment proceedings under s.147 could be initiated within limitation by applying statutory saving/exclusion of time, and whether sanction under s.151(i) was valid. The HC held that the revenue was entitled to exclusion of the period from 01.04.2021 to 20.03.2022 for computing limitation; upon such exclusion, the s.148 notice dated 25.09.2024 was within time, and the sanction granted by the Principal Commissioner under s.151(i) complied with law. The SC found no error in this determination and declined interference, resulting in dismissal of the challenge and sustaining the reassessment notice and sanction.
The Supreme Court declined to exercise its jurisdiction to disturb the High Court's decision, holding: "We see no ground to interfere with the impugned judgement and order of the High Court." On that basis, the Court dismissed the petition: "Hence, the petition stands dismissed." The order reflects a determination that the case did not warrant appellate interference, and consequently no further relief was granted. Any pending application(s) connected with the petition were also disposed of in light of the dismissal.
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