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The High Court held that the reassessment order dated 12.05.2023 and subsequent proceedings were invalid as they were beyond the statutory limitation period prescribed u/s 153(2) of the Income Tax Act. For notices issued u/s 148 on or after 01.04.2019, the reassessment must be completed within twelve months from the end of the financial year in which the notice was issued. Since the notice was issued on 29.03.2021, the reassessment should have been completed by 31.03.2022. However, the reassessment order was passed on 12.05.2023, well beyond the twelve-month period, rendering it non-est and invalid. The Court rejected the Revenue's contention regarding the applicability of the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, as the notice was issued within the extended limitation period under that Act. Consequently, the Court ruled in favor of the assessee.
The High Court held that the reassessment order dated 12.05.2023 and subsequent proceedings were invalid as they were beyond the statutory limitation period prescribed u/s 153(2) of the Income Tax Act. For notices issued u/s 148 on or after 01.04.2019, the reassessment must be completed within twelve months from the end of the financial year in which the notice was issued. Since the notice was issued on 29.03.2021, the reassessment should have been completed by 31.03.2022. However, the reassessment order was passed on 12.05.2023, well beyond the twelve-month period, rendering it non-est and invalid. The Court rejected the Revenue's contention regarding the applicability of the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, as the notice was issued within the extended limitation period under that Act. Consequently, the Court ruled in favor of the assessee.
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