https://www.taxtmi.com/highlights?id=83926 The High Court held that the impugned notice issued u/s 148 of the Act was beyond the time limitation prescribed u/s 149(1). The Revenue's contention that the non-obstante clause u/s 150 permitted issuance of the notice, premised on the assumption that the High Court's previous order dismissing the Revenue's appeal contained findings and directions for commencing proceedings u/s 147, was rejected. The Court clarified that its previous order could not be construed as permitting reopening of assessments beyond the period stipulated u/s 149(1) or where necessary conditions for invoking Sections 147 and 148 were not satisfied. Consequently, the time limitation u/s 149(1) was applicable, rendering the impugned notice invalid. en-us Thu, 12 Dec 2024 08:55:57 +0530 Thu, 12 Dec 2024 08:55:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=83926 The High Court held that the impugned notice issued u/s 148 of the Act was beyond the time limitation prescribed u/s 149(1). The Revenue's contention that the non-obstante clause u/s 150 permitted issuance of the notice, premised on the assumption that the High Court's previous order dismissing the Revenue's appeal contained findings and directions for commencing proceedings u/s 147, was rejected. The Court clarified that its previous order could not be construed as permitting reopening of assessments beyond the period stipulated u/s 149(1) or where necessary conditions for invoking Sections 147 and 148 were not satisfied. Consequently, the time limitation u/s 149(1) was applicable, rendering the impugned notice invalid. Highlights Income Tax Thu, 12 Dec 2024 08:55:57 +0530 https://www.taxtmi.com/highlights?id=83926