TaxTMI Login
AI OCR ✕Convert scanned orders, printed notices, PDFs and images into clean, searchable, editable text within seconds. Starting at 2 Credits/page
Try Now →Just a moment...
AI OCR ✕Convert scanned orders, printed notices, PDFs and images into clean, searchable, editable text within seconds. Starting at 2 Credits/page
Try Now →
Press 'Enter' to add multiple search terms. Rules for Better Search
Use comma for multiple locations.
---------------- For section wise search only -----------------
Accuracy Level ~ 90%
of 
Press 'Enter' after typing page number.
of Press 'Enter' after typing page number.
No Folders have been created
Are you sure you want to delete "My most important" ?
NOTE:
of Press 'Enter' after typing page number.
of Press 'Enter' after typing page number.
All Case Laws
of Press 'Enter' after typing page number.
of Press 'Enter' after typing page number.
All Case Laws
Note
Bookmark
Share
Don't have an account? Register Here
of Press 'Enter' after typing page number.
Issues: Whether the notice issued under section 148 for the relevant assessment year was barred by limitation and whether the consequent reassessment was invalid.
Analysis: The notice under section 148 was issued on 28.04.2022 for assessment year 2015-16. The applicable limitation under section 149(1)(b) required issuance within six years from the end of the assessment year, that is, on or before 31.03.2022. Since the notice was issued after the expiry of that period, it was time-barred. Once the notice itself was invalid, the reassessment proceedings founded on it could not survive.
Conclusion: The notice under section 148 was barred by limitation and the consequent reassessment order was invalid. The appeal was therefore allowed in favour of the assessee.
TaxTMI 
TaxTMI 
