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    <title>2025 (3) TMI 1392 - ALLAHABAD HIGH COURT</title>
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    <description>A demand order and show cause notice issued under Section 73 for assessment year 2017-18 were held time-barred because the order under Section 73(9) had to be passed within three years from the extended due date for furnishing the annual return under Section 44(1). As that due date stood extended to 05.02.2020, limitation expired on 05.02.2023. A later notification dated 24.04.2023 could not retrospectively revive a limitation period that had already expired, so the impugned proceedings were without jurisdiction and were quashed.</description>
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      <description>A demand order and show cause notice issued under Section 73 for assessment year 2017-18 were held time-barred because the order under Section 73(9) had to be passed within three years from the extended due date for furnishing the annual return under Section 44(1). As that due date stood extended to 05.02.2020, limitation expired on 05.02.2023. A later notification dated 24.04.2023 could not retrospectively revive a limitation period that had already expired, so the impugned proceedings were without jurisdiction and were quashed.</description>
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