https://www.taxtmi.com/caselaws?id=774909 The Delhi HC held that a notice under Section 148 for reopening assessment was barred by limitation. The court ruled that prior to amendments, such notices could only be issued within 6 years from the end of the relevant assessment year per Section 149's first proviso. The Revenue's contention that the notice was valid under Section 153 due to prior court directions was rejected, as the Revenue must take proper legal steps within the limitation period. The court emphasized that failure to follow proper procedure cannot extend statutory limitation periods. The reassessment proceedings were consequently set aside in favor of the assessee. en-us Thu, 10 Jul 2025 00:00:00 +0530 Wed, 16 Jul 2025 08:17:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774909 The Delhi HC held that a notice under Section 148 for reopening assessment was barred by limitation. The court ruled that prior to amendments, such notices could only be issued within 6 years from the end of the relevant assessment year per Section 149's first proviso. The Revenue's contention that the notice was valid under Section 153 due to prior court directions was rejected, as the Revenue must take proper legal steps within the limitation period. The court emphasized that failure to follow proper procedure cannot extend statutory limitation periods. The reassessment proceedings were consequently set aside in favor of the assessee. Case-Laws Income Tax Thu, 10 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774909