https://www.taxtmi.com/caselaws?id=462867 The Delhi HC held that the reopening assessment notice issued beyond the limitation period under Section 149(1) was invalid. The Revenue argued the notice was valid under Section 150's non-obstante clause, claiming it was based on findings from the SC decision in Abhisar Buildwell (P.) Ltd., which allowed reassessment powers under Sections 147/148 even in search cases under Section 132. However, the HC rejected this contention, following its earlier decision in ARN Infrastructures India Ltd., where a similar argument was dismissed. The court ruled that the Abhisar Buildwell decision did not constitute a finding or direction justifying notices beyond the statutory limitation period, making the impugned notice time-barred and invalid. en-us Fri, 02 May 2025 00:00:00 +0530 Mon, 21 Jul 2025 19:11:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462867 The Delhi HC held that the reopening assessment notice issued beyond the limitation period under Section 149(1) was invalid. The Revenue argued the notice was valid under Section 150's non-obstante clause, claiming it was based on findings from the SC decision in Abhisar Buildwell (P.) Ltd., which allowed reassessment powers under Sections 147/148 even in search cases under Section 132. However, the HC rejected this contention, following its earlier decision in ARN Infrastructures India Ltd., where a similar argument was dismissed. The court ruled that the Abhisar Buildwell decision did not constitute a finding or direction justifying notices beyond the statutory limitation period, making the impugned notice time-barred and invalid. Case-Laws Income Tax Fri, 02 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462867