Courier operator transshipping imported goods via designated air carrier, under transshipment bonds and strict Customs supervision, approved until 17....
HC held that the second reopening notice dated 03.10.2008 for AY 2003-04 was wholly without jurisdiction and barred by limitation under Section 153(2) read with Sections 147 and 148 of the Income-tax Act. Once the first reassessment notice issued on 28.03.2007 triggered the statutory nine-month period, the assessment had to be completed by 31.12.2007. Revenue's failure to do so could not be cured by issuing a fresh notice. HC quashed the second notice, declared the reassessment proceedings void ab initio, and held that the assessment for AY 2003-04 had attained finality upon expiry of the statutory deadline.
HC held that the second reopening notice dated 03.10.2008 for AY 2003-04 was wholly without jurisdiction and barred by limitation under Section 153(2) read with Sections 147 and 148 of the Income-tax Act. Once the first reassessment notice issued on 28.03.2007 triggered the statutory nine-month period, the assessment had to be completed by 31.12.2007. Revenue's failure to do so could not be cured by issuing a fresh notice. HC quashed the second notice, declared the reassessment proceedings void ab initio, and held that the assessment for AY 2003-04 had attained finality upon expiry of the statutory deadline.
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