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HC held that the second Section 148 notice was issued beyond the statutory limitation period of four years from the end of AY 2016-17. The first Section 148 notice was validly issued on 23.06.2021, six days before the extended limitation deadline. However, the subsequent second Section 148 notice was time-barred. Consequently, all proceedings initiated pursuant to the second notice were set aside. The court relied on precedential rulings and statutory interpretations, specifically focusing on procedural time constraints in tax reassessment proceedings. The decision effectively invalidated the subsequent reassessment notice due to non-compliance with prescribed limitation periods.
HC held that the second Section 148 notice was issued beyond the statutory limitation period of four years from the end of AY 2016-17. The first Section 148 notice was validly issued on 23.06.2021, six days before the extended limitation deadline. However, the subsequent second Section 148 notice was time-barred. Consequently, all proceedings initiated pursuant to the second notice were set aside. The court relied on precedential rulings and statutory interpretations, specifically focusing on procedural time constraints in tax reassessment proceedings. The decision effectively invalidated the subsequent reassessment notice due to non-compliance with prescribed limitation periods.
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