https://www.taxtmi.com/caselaws?id=458570 The Gujarat HC held that reassessment notices under section 148 for AY 2013-14 and 2014-15 issued between April-June 2021 were time-barred and without jurisdiction. The court ruled that the six-year limitation period from the old regime continued to apply, making notices issued beyond March 2020 (for AY 2013-14) and March 2021 (for AY 2014-15) invalid. The HC rejected the Revenue's reliance on CBDT notifications extending time limits, holding that secondary legislation cannot override principal legislation. All such notices were declared illegal and beyond the permissible timeline. en-us Mon, 13 Mar 2023 00:00:00 +0530 Wed, 06 Nov 2024 19:52:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=458570 The Gujarat HC held that reassessment notices under section 148 for AY 2013-14 and 2014-15 issued between April-June 2021 were time-barred and without jurisdiction. The court ruled that the six-year limitation period from the old regime continued to apply, making notices issued beyond March 2020 (for AY 2013-14) and March 2021 (for AY 2014-15) invalid. The HC rejected the Revenue's reliance on CBDT notifications extending time limits, holding that secondary legislation cannot override principal legislation. All such notices were declared illegal and beyond the permissible timeline. Case-Laws Income Tax Mon, 13 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=458570