https://www.taxtmi.com/caselaws?id=774696 The Delhi HC held that the AO's notice under Section 148 was issued beyond the statutory limitation period. The court found that while the AO initially decided against reopening assessment, this decision was later revised based on specified authority approval. Since the case didn't fall under Section 149(1)(b), the three-year limitation under Section 149(1)(a) applied, expiring on 31.03.2023. Although the AO issued a Section 148A(b) notice on the last date, considering the mandatory exclusion periods under the Fifth and Sixth provisos to Section 149(1), the final notice was time-barred. The petition was allowed following the precedent in Raminder Singh case. en-us Mon, 07 Jul 2025 00:00:00 +0530 Sat, 12 Jul 2025 08:40:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774696 The Delhi HC held that the AO's notice under Section 148 was issued beyond the statutory limitation period. The court found that while the AO initially decided against reopening assessment, this decision was later revised based on specified authority approval. Since the case didn't fall under Section 149(1)(b), the three-year limitation under Section 149(1)(a) applied, expiring on 31.03.2023. Although the AO issued a Section 148A(b) notice on the last date, considering the mandatory exclusion periods under the Fifth and Sixth provisos to Section 149(1), the final notice was time-barred. The petition was allowed following the precedent in Raminder Singh case. Case-Laws Income Tax Mon, 07 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774696